G.R. No. 217542 - Ferdez y Medina vs. People

In 1978, petitioner Daniel F. Tiangco was engaged as an insurance agent by the Philippine branch of Sun Life Assurance of Canada, which was later renamed Sun Life of Canada (Philippines), Inc. (SLOCPI).
In 2000, as part of its expansion in the pre-need industry, Sun Life Financial established Sun Life Financial Plans, Inc. (SLFPI) and engaged Tiangco as a Sales Consultant to market its pre-need plans in the Philippines.

On December 10, 2003, after a due and proper investigation of a sexual harassment complaint filed by Marigay S. Rivera, both Tiangco’s SLOCPI Agent’s Agreement and SLFPI Sales Consultant’s Agreement were terminated.
On July 10, 2004, Tiangco demanded commission payments from SLFPI, SLOCPI, and Rizalina Mantaring (President of both companies), claiming unpaid remunerations mostly relating to renewal commissions on a group life policy, as well as educational and pension plans, amounting to P496,148.70.

Aggrieved by the denial of his claims, Tiangco filed a Complaint for Sum of Money with Damages before the Regional Trial Court (RTC) of Makati City, Branch 133.
The RTC, in its Decision dated November 16, 2015, dismissed Tiangco’s complaint and the compulsory counterclaims filed by the respondents due to a lack of preponderant proof supporting his claims.

He claimed he did not sign the Consultant’s Agreement.
He contended that, as a signatory of the SLOCPI Agent’s Agreement with 15 years of service, he was entitled to commissions, bonuses, and other compensations even after termination.
He argued that SLFPI and SLOCPI are effectively one entity, warranting that the compensation scheme applicable to SLOCPI should equally apply to SLFPI.

Affirmed the RTC ruling by showing that Tiangco had indeed signed, acknowledged, and was bound by the Consultant’s Agreement; evidence included his signature on the SLFPI Briefing Certificate.
Ruled that there was no basis for piercing the corporate veil between SLFPI and SLOCPI, as mere interlocking officers and intertwined policies did not justify treating the companies as a single entity.
Upheld the RTC’s hold on the cash bond claim, ruling that Tiangco failed to secure the necessary clearance from the respondents for its release.

Whether Tiangco is entitled to the commission earned after his termination, particularly under the assertion that SLFPI and SLOCPI are one entity due to shared management and policies.

Whether Tiangco is entitled to the refund of his cash bond amounting to P50,000.00 given that he allegedly secured clearance, notwithstanding the respondents’ contention that no such clearance was properly obtained.