Case Digest (G.R. No. 157906)
Facts:
Renato Real v. Sangu Philippines, Inc. and/or Kiichi Abe, G.R. No. 168757, January 19, 2011, the Supreme Court First Division, Del Castillo, J., writing for the Court. Petitioner Renato Real (formerly Manager) filed a complaint for illegal dismissal together with 29 co-complainants against employer Sangu Philippines, Inc. and respondent Kiichi Abe (Vice‑President and General Manager). The complaints, later consolidated, arose from petitioner’s removal as Manager by Board Resolution No. 2001‑03 and a termination letter dated March 26, 2001 stating grounds of absenteeism, loss of trust and confidence, and cost‑cutting.Before the Labor Arbiter, petitioner claimed he was neither notified of the board meeting nor formally charged; respondents alleged sustained misconduct, absenteeism, an incident at a client’s premises, and that petitioner had formed a competing company and incited strikes. The Labor Arbiter, in a Decision dated June 5, 2003, declared petitioner and his co‑complainants illegally dismissed and ordered reinstatement, backwages and attorney’s fees, finding absence of proof of cause and lack of due process.
Respondents appealed to the National Labor Relations Commission (NLRC), which in a Decision dated February 13, 2004 found petitioner to be both stockholder and corporate officer (relying on petitioner’s admission and the corporation’s General Information Sheet) and dismissed Renato Real’s complaint for lack of jurisdiction, while ordering the other complainants to report back without backwages. Petitioner sought certiorari relief from the Court of Appeals (CA), which in a Decision dated June 28, 2005 (per Tria Tirona, J.) dismissed the petition and affirmed the NLRC’s dismissal insofar as it concerned Renato Real.
Petitioner then filed this Petition for Review on Certiorari under ...(Subscriber-Only)
Issues:
- Is petitioner’s complaint for illegal dismissal an intra‑corporate controversy and therefore beyond the jurisdiction of the Labor Arbiter?
- Was petitioner a corporate officer such that an intra‑corporate relationship existed between him and the corporation?
- If not intra‑corporate, was petitioner validly dismissed and, if not, what r...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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