Facts:

• Ernesto Abragar filed a complaint on April 29, 2003, before the Regional Arbitration Branch of the NLRC in San Fernando City, Pampanga.
• The complaint was against a Marble Center located at TESDA, Guiguinto, Bulacan, and his supervisor, Philip Bronio.
• Abragar alleged underpayment and non-payment of salaries, service incentive leave, and 13th-month pay.
• The complaint was later amended to include constructive dismissal, non-payment of separation pay and retirement pay, and payment of damages and attorney's fees.
• During the mandatory conference, Bronio appeared as the representative of the Center, but no amicable settlement was reached.
• Abragar claimed he was hired in September 1997 as a marble operator and was constructively dismissed in December 2002 when his working days and pay were reduced.
• The Center and Bronio failed to submit their position paper, leading to a default judgment by the Labor Arbiter (LA) on July 30, 2004, in favor of Abragar.
• The LA found that Abragar was constructively dismissed and awarded him separation pay, back wages, salary differential, service incentive leave pay, and 13th-month pay.
• Bronio's motion for reconsideration and petition for relief from judgment were dismissed by the NLRC, making the LA's decision final and executory.
• TESDA later intervened, arguing that the Center was a non-juridical entity and that the proper parties were not impleaded.
• The NLRC granted TESDA's appeal, quashed the writ of execution, and remanded the case for further proceedings.
• The Court of Appeals (CA) reversed the NLRC's decision, reinstating the LA's judgment.
• TESDA then filed a Petition for Review on Certiorari before the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled in favor of TESDA, reversing and setting aside the CA's decision.
• The case was remanded to the Regional Arbitration Branch of the NLRC for the inclusion of TESDA, the Department of Trade and Industry (DTI), the Marble Association of the ...(Unlock)

Ratio:

• The Supreme Court held that the Marble Center is not a juridical entity and thus has no legal capacity to be sued.
• Only natural or juridical persons, or entities authorized by law, may be parties in a civil action.
• The Center, being a training and skill development facility operated by TESDA, should not have been impleaded as a party.
• The ...continue reading