G.R. No. 214762 - People vs. Ronquillo

The petitions involve Sara Lee Philippines, Inc. (SLPI), Aris Philippines, Inc. (Aris), Sara Lee Corporation (SLC), Atty. Cesar Cruz (Cruz), and Fashion Accessories Philippines, Inc. (FAPI) (collectively, the Corporations) as petitioners. Emilinda D. Macatlang and 5,983 other former employees of Aris (respondents) filed counter-petitions.
SLPI is a domestic corporation manufacturing personal care products and is a subsidiary of SLC. Aris produces gloves and apparel; FAPI manufactures knitted products; SLC is a U.S. corporation and controlling stockholder of the other corporations. Cruz was external counsel and later VP and Director of Aris.
Emilinda D. Macatlang represents the former employees whose employment was terminated upon Aris’s closure.

On 4 September 1995, Aris filed a Notice of Permanent Closure effective 9 October 1995, informing all employees.
The Aris Philippines Workers Confederation of Filipino Workers (Union) representing 5,984 employees staged a strike alleging violations including duty to bargain collectively, union busting, and illegal closure.
After conciliation, Aris agreed to pay benefits totaling approximately P419 million plus an additional P15 million benevolent fund to the union.
FAPI was incorporated on 26 October 1995, allegedly continuing business operations of Aris. A total of 63 complaints for illegal dismissal were consolidated, including SLC, SLPI, FAPI, and Cruz as respondents, besides Aris.
The complainants claimed that FAPI continued Aris’s business, transferring equipment, employees, contractors, and export quotas, intending to defeat employees’ security of tenure. The Corporations denied all claims, stating separate business operations and lawful closure.

On 30 October 2004, the Labor Arbiter found the dismissal of 5,984 complainants illegal and awarded damages worth P3,453,664,710.86 including separation pay, back wages, moral and exemplary damages, and attorney’s fees.
The Corporations filed notices of appeal seeking reduction of the appeal bond from P3.45 billion to a lower amount, citing impossibility of securing insurance for the full amount and financial insufficiency, as well as partial payments already made.
The Corporations posted P4.5 million as appeal bond; the NLRC ordered additional P4.5 million to be posted, totaling P9 million.
Emilinda D. Macatlang and others opposed the motion for reduction, insisting on the statutory bond amount.
The NLRC granted bond reduction; however, the Court of Appeals reversed this and ordered an additional P1 billion bond to be posted, citing protection for employees and likelihood of evasive tactics by employers.

The employees filed two petitions for certiorari before the Court of Appeals, one by Macatlang et al. and another by Abelardo et al., leading to issues of forum shopping.
Abelardo petition was dismissed by the Court of Appeals for procedural defects.
The controversy over appeal bond amount and posting persisted, leading to six consolidated petitions before the Supreme Court.
Procedural issues such as authority to file, failure to state material dates, and validity of summons by publication were raised.

Whether the filing of two petitions for certiorari by the employees constitutes forum shopping.
Whether Emilinda D. Macatlang was duly authorized to sign the verification and certification of non-forum shopping.
Whether the petition should be dismissed for failure to state the material dates.
Whether service of summons by publication on SLC was defective.
Whether the subsequent NLRC ruling on the merits during pendency of the petition renders the case moot and academic.
Whether the appeal bond requirement under Article 223 of the Labor Code may be reduced given the enormous amount of the monetary award.