G.R. No. 203355 - Rosales vs. New A.N.J.H. Enterprises

Petitioners: Leo R. Rosales, Edgar Solis, Jonathan G. Raniola, Lito Feliciano, Raymundo Didal, Jr., Nestor Salin, Arnulfo S. Abril, Ruben Flores, Dante Ferma, and Melchor Selga, former employees of New ANJH Enterprises.
Respondents: New ANJH Enterprises (a sole proprietorship owned by respondent Noel Awayan), NH Oil Mill Corporation (NH Oil), and members of the Awayan family.

On February 11, 2010, Noel Awayan informed DOLE Region IV-A of New ANJH’s impending cessation of operations due to dwindling capital, sale of assets to NH Oil, and planned termination of thirty-three (33) employees.
On February 13, 2010, the 33 affected employees including petitioners were notified of the plan and given notices dated February 12, 2010, stating closure effective March 15, 2010, and sale of assets to a corporation, with an offer of separation pay.
On March 5, 2010, Noel sold New ANJH’s assets (equipment, machines, tools) for P950,000 to NH Oil, represented by Heidi A. Ilagan, Noel’s sister.

NH Oil’s Articles of Incorporation were prepared on January 27, 2010.
Noel held more than two-thirds (2/3) of the subscribed capital stock, with remaining shares owned by Heidi and other family members.

March 8, 2010, respondents filed a "Letter Request for Intervention" before NLRC Sub-Regional Arbitration Branch No. IV (NLRC-SRAB-IV), requesting to be guided in payment of separation benefits.
Petitioners received and accepted separation pay with corresponding Quitclaims and Releases between March 16 and 29, 2010.
Labor Arbiter (LA) Melchisedek A. Guan issued four Orders dismissing the labor dispute "with prejudice on ground of settlement."

Petitioners filed a complaint for illegal dismissal (NLRC Case No. RAB-IV-04-00649-10-L) alleging that New ANJH ceased operations only to reopen as NH Oil with the same management and machinery, arguing that the sale was a circumvention of their security of tenure.
Executive Labor Arbiter (ELA) Generoso V. Santos found in favor of petitioners on April 29, 2011, ruling the dismissal illegal, ordering reinstatement and payment of full backwages less separation pay.
Respondents filed an appeal and a Verified Motion to Reduce Bond; posted 60% of award as appeal bond.

NLRC initially denied the motion to reduce bond and dismissed the appeal for non-perfection but later reversed itself, finding the sale valid, dismissal not illegal, and the complaint barred by res judicata based on the LA Guan’s Orders.
The Court of Appeals (CA) affirmed the NLRC’s resolutions, holding that the Orders of LA Guan were final and binding, and the appeal bond was substantially complied with.

Petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45.

Whether the CA and NLRC correctly ruled that the appeal from the decision of the Executive Labor Arbiter was not perfected due to inadequate posting of appeal bond and whether filing a motion to reduce bond suspends the period to perfect appeal.

Whether the Orders issued by Labor Arbiter Melchisedek A. Guan dismissing the labor dispute on grounds of settlement bar petitioners’ illegal dismissal complaint under the doctrine of res judicata.

Whether the sale of New ANJH’s assets to NH Oil Mill, owned and managed by the same family, constitutes a genuine sale to justify the termination of petitioners or is a circumvention of their security of tenure warranting application of the piercing the corporate veil doctrine.