G.R. No. 184517 - SME Bank, Inc. vs. De Guzman

Background
Respondent-employees Elicerio Gaspar, Ricardo Gaspar Jr., Eufemia Rosete, Fidel Espiritu, Simeon Espiritu Jr., and Liberato Mangoba were regular employees of Small and Medium Enterprise Bank, Inc. (SME Bank).
Original principal shareholders and directors of SME Bank were Eduardo M. Agustin Jr. and Peregrin T. de Guzman.
In June 2001, SME Bank faced financial difficulties and its officials negotiated a sale of 86.365% of its shares to petitioners Abelardo P. Samson, Olga Samson, and Aurelio Villaflor Jr.

Letter Agreements and Resignations
Pre-sale “Letter Agreements” required Agustin and De Guzman to “terminate/retire the employees we mutually agree upon” upon share transfer and waived directors’ retirement benefits.
General Manager Simeon Espiritu induced the six rank-and-file employees to tender resignation letters dated 27 August 2001, promising re-employment by the new management; Eufemia Rosete submitted both a resignation (27 August 2001) and a retirement letter (September 2001).
On 11 September 2001, the Samson group acquired the controlling shares of SME Bank, appointed Villaflor as president, but only rehired Simeon Espiritu Jr., who resigned again in October 2001.

Labor Proceedings
The six employees filed complaints before the Labor Arbiter for illegal dismissal, unfair labor practice, and nonpayment of separation pay and other benefits.
The Labor Arbiter (27 October 2004) held Agustin and De Guzman liable for separation pay (₱339,403) but dismissed claims against the Samson group.
The NLRC (8 May 2006) reversed in part, finding illegal dismissal by virtue of share transfer, and held all respondents—Agustin, De Guzman, and the Samson group—jointly and severally liable for backwages, separation pay, moral and exemplary damages, and attorney’s fees.
The Court of Appeals (CA) denied the sellers’ and the Samson group’s separate certiorari petitions (Decisions of March 2008 and January 2008; Reconsideration resolutions of September 2008 and February 2009).
This Court consolidated the two Rule 45 Petitions for review on certiorari and granted oral arguments.

Whether respondent-employees were illegally dismissed despite having tendered resignation or retirement letters.
Whether a mere change in the corporation’s equity composition (stock sale) constitutes a just or authorized cause for dismissal under the Labor Code.
Which parties among SME Bank, Agustin, De Guzman, the Samson group, and Villaflor are liable for illegal dismissal.
The extent of relief to which the illegally dismissed employees are entitled.