Case Digest (G.R. No. 128003)
Facts:
In Rubberworld (Phils.), Inc. v. National Labor Relations Commission, G.R. No. 128003, July 26, 2000, the Supreme Court First Division, Pardo, J., writing for the Court, resolved whether labor proceedings could continue despite an SEC rehabilitation order.Rubberworld (Phils.), Inc. (petitioner), a footwear, bags and garments manufacturer, filed a notice of temporary shutdown on August 26, 1994, effective September 26, 1994, but was forced to close earlier. Six employees — Aquilino Magsalin, Pedro Manibo, Ricardo Borja, Benjamin Camitan, Alicia M. San Pedro, and Felomena B. Tolin (respondent-complainants) — filed a complaint for illegal dismissal and non-payment of separation pay with the National Labor Relations Commission (NLRC) docketed as NLRC NCR Case 00-11-08125-94 on November 11, 1994.
On November 22, 1994, Rubberworld filed with the Securities and Exchange Commission (SEC) a petition for declaration of suspension of payments and a proposed rehabilitation plan (SEC Case No. 11-94-4920). On December 28, 1994, the SEC ordered that, with the creation of a Management Committee, “all actions for claims against Rubberworld Philippines, Inc. pending before any court, tribunal, office, board, body, Commission or sheriff are hereby deemed SUSPENDED,” and that pending incidents for injunctions, writs of attachment, foreclosures, and the like were moot.
Petitioners moved before the labor arbiter on January 24, 1995 to suspend the labor proceedings pursuant to the SEC order; the labor arbiter did not rule on that motion and instead required position papers and thereafter, on December 10, 1995, rendered a decision declaring the shutdown illegal and awarding separation pay, P50,000.00 in moral damages and P30,000.00 in exemplary damages to each complainant, plus 10% attorney’s fees. Petitioners appealed to the NLRC on February 5, 1996, alleging abuse of discretion and errors of fact.
The NLRC, by resolution dated August 30, 1996 (Raul T. Aquino, ponente), affirmed the labor-arbiter’s decision but modified it by deleting the awards of moral and exemplary damages; its denial of petitioners’ motion for reconsideration followed on November 20, 1996. Petitioners filed a petition with the Supreme Court on February 18, 1997; the Court gave due course on September 22, 1999 and trea...(Pro-only)
Issues:
- Whether the Department of Labor and Employment, the labor arbiter, and the NLRC may legally proceed to hear and decide labor claims against a corporation while the SEC has suspended all actions pursuant to a rehabilitation order (procedural/jurisdictional issue)?
- If not, whether the NLRC’s resolution and the labor-arbiter’s decision are void for lack or excess of jurisdic...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)