G.R. No. 180147 - Sara Lee Philippines, Inc. vs. Macatlang

The case involves multiple petitioners—Sara Lee Philippines, Inc. (SLPI), Aris Philippines, Inc. (Aris), Sara Lee Corporation (SLC), Cesar C. Cruz, and Fashion Accessories Phils., Inc. (FAPI)—and 5,984 former rank-and-file employees of Aris.
The dispute originated from the labor arbiter’s decision on 30 October 2004 that declared the dismissal of the 5,984 employees illegal and awarded them monetary benefits amounting to approximately P3.45 billion.
The petitioners filed several motions including a Motion for Reconsideration with an Urgent Petition for the Court’s Approval of the pending Motion for Leave of Court to File and Admit the Statement and Confession of Judgment to buy peace and/or secure against any possible contingent liability.
A separate Motion for Reconsideration was filed by FAPI and a Manifestation of Conformity to the Motion for Leave to File and Admit the Confession of Judgment was also submitted by petitioner SLC.

On 4 June 2014, the Supreme Court directed SLPI, Aris, SLC, and Cesar C. Cruz (collectively “the Corporations”) to post an appeal bond of P725 million within ten days from receipt of the decision.
The decision also vacated the NLRC Resolution dated 19 December 2006 for being procedurally premature, which had formerly set aside the Labor Arbiter’s decision.
The Court noted that while the NLRC had issued its resolution, it must now act with dispatch in resolving the merits of the case upon the perfection of the appeal by the Corporations.

Procedural issues arose regarding whether the Labor Arbiter had acquired jurisdiction over petitioners due to alleged invalid service of summons and non-impleading of certain petitioners during earlier proceedings.
The petitioners challenged the existence of an employer-employee relationship between SLPI, SLC, and Cesar C. Cruz and the respondents.
Petitioners also argued that the pending motions should have terminated the proceedings below if the compromise agreement (or its equivalent confession of judgment) had been adjudicated, thereby avoiding further delay.

The decision set an appeal bond at P725 million, meant to secure potential liabilities pending the final resolution of the case.
The Corporations advanced a compromise agreement (or confession of judgment) with detailed terms for the payment of a total of P342,284,800.00 to the 5,984 former employees, which when computed amounts to roughly 10% of the original judgment award.
The document detailed elaborate payment instructions, conditions for claiming the deposited funds, and the eventual reversion of unclaimed funds to the Corporations after a two-year period.
The compromise was critiqued as grossly disproportionate, as the amount per employee (after deducting attorney’s fees) was significantly lower than the monetary award previously granted by the labor arbiter.

Petitioners argued that the Court failed to consider the earlier motion and the consent of the respondents regarding the compromise agreement, which could have terminated the case.
They raised multiple due process challenges, including lack of proper jurisdiction and service of summons on SLPI, SLC, and Cesar C. Cruz.
They contended that there was no legal prohibition on the NLRC issuing its earlier resolution given the absence of a TRO or writ of preliminary injunction.
The petitioners also questioned the applicability of the “10% rule” from McBurnie v. Ganzon, asserting that the bond requirement should only be 10% of the monetary award, rather than the full P725 million as set.

The dispute involved a consolidation of cases and motions spanning from challenges to the NLRC’s procedural order to objections over alleged forum shopping between the Abelardo petition and the Macatlang petition.
The petitioners’ various arguments addressed legal doctrines on judicial courtesy, res judicata, and prescription of money claims under Article 291 of the Labor Code.
The Court was confronted with reconciling conflicting interests: ensuring adequate protection for the employees while avoiding any unjust enrichment or undervaluation of the appeal bond requirement.

Whether the Court erred in not considering the Motion for Leave of Court to File and Admit the Confession of Judgment (or compromise agreement) which was filed before the receipt of the June 4, 2014 Decision, potentially terminating the cases.
Whether the Court properly ruled on the alleged due process violations, specifically regarding:

The non-acquisition of jurisdiction by the Labor Arbiter over petitioners who were not properly served or impleaded.
The absence of an employer-employee relationship between SLPI, SLC, Cesar C. Cruz, and the respondents.

Whether the NLRC had the legal authority to issue its Resolution of December 19, 2006, and how judicial courtesy might affect that power.
Whether the appeal bond amount of P725 million is an appropriate and necessary measure to secure potential liabilities, in light of the contention that a 10% bond requirement should suffice as per McBurnie v. Ganzon.
Whether the filing and designation of the compromise agreement/confession of judgment should have prevented further proceedings and if it meets the standards of a valid compromise under the law.
Whether the issues of prescription, res judicata, and forum shopping (as evidenced by the Abelardo petition versus the Macatlang petition) should bar the actions or motions of the petitioners.