Case Digest (G.R. No. 193034) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case, titled San Felipe Neri School of Mandaluyong, Inc. et al. vs. National Labor Relations Commission et al., arose from the events leading up to an employment dispute involving the private respondents, a group of former teachers at the San Felipe Neri School of Mandaluyong, Inc. After the school executed a Deed of Absolute Sale transferring ownership of its properties to the Roman Catholic Archbishop of Manila (RCAM) on April 18, 1981, the private respondents reported for work in May 1981 but discovered that the school was under new ownership and required them to reapply as employees under probationary status. They had not received prior notice regarding the sale or its implications for their employment. Consequently, the private respondents filed a complaint with the Labor Arbiter against the petitioners (the former owners of the school and its officials) and RCAM. The Labor Arbiter ruled in favor of the private respondents on March 26, 1984, ordering the petitioners to Case Digest (G.R. No. 193034) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
The petition involves a dispute over the payment of separation pay to former teacher-employees of San Felipe Neri School of Mandaluyong, Inc. The petitioners—incorporators, stockholders, and trustees of the school—alleged that there was no termination of the employment of the teachers, as the sale of the school's assets to the Roman Catholic Archbishop of Manila (RCAM) did not disrupt individual employment. On April 18, 1981, the school executed a Deed of Absolute Sale transferring its buildings, equipment, and other properties to RCAM. However, the sale did not include clear provisions regarding the employment status of the existing teaching staff. When the private respondents (former teachers) reported for work in May 1981 for the school year's opening, they discovered that the school was already under new ownership and that they were required to re-apply for employment, being relegated to probationary status with their previous services unrecognized. Feeling aggrieved, the teachers filed a complaint before the Labor Arbiter for separation pay, differential pay, and other claims. The Labor Arbiter rendered a decision in March 1984 in favor of the teachers, holding the petitioners accountable for the payment of separation pay. The petitioners, arguing that change of ownership did not equate to termination of employment and that they were not the direct employers, subsequently appealed to the NLRC. The NLRC, in resolutions dated February 12, 1987, and April 7, 1987, affirmed the Labor Arbiter’s decision, ruling that the sale effectively resulted in a closure of the school under the petitioners and thus terminated the employment of the teachers, entitling them to separation pay.Issues:
The central issue in the case is whether the sale and transfer of the San Felipe Neri School of Mandaluyong, Inc. to the RCAM, which led to a change in management and the re-hiring of teachers under new terms, constitutes a termination of the employees’ service entitling them to separation pay. Specifically, the petitioners argued that:- There was no interruption or termination in employment since the RCAM continued the school’s operations.
- They, as part of the school’s corporate structure, should not be held liable, given the recognized separate personality of the corporation.
- Jurisprudence (notably the GENBANK and TARELCO cases) supported the notion that a mere change of ownership does not affect the security of tenure.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)