Case Digest (G.R. No. 163786) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Times Transportation Company, Inc. v. Santos Sotelo, et al. (G.R. No. 163786, February 16, 2005), petitioner Times Transportation Company, Inc. (“Times”), a land‐transport corporation, faced labor unrest when its certified union, the Times Employees Union (TEU), struck twice in 1997—first on March 3–12 and again beginning October 17—over alleged unfair labor practices and management’s refusal to bargain collectively. Prior to the second strike, Times implemented a retrenchment program, serving notices on September 16, 1997 to respondents (employees including Santos Sotelo and dozens of co-respondents), and later dismissed 123 strikers by notices dated October 26 and November 24, 1997. The Department of Labor and Employment issued return-to-work orders and referred the dispute to the National Labor Relations Commission (NLRC), which on May 21, 1998 declared the first strike legal but the second illegal, thus validating the dismissal of 23 strikers. After consolidation of relat Case Digest (G.R. No. 163786) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Times Transportation Company, Inc. (Times) was a land transportation corporation that closed in 1997.
- Respondents were employees of Times and members of the Times Employees Union (TEU), duly certified as sole bargaining agent after a certification election on July 1, 1997.
- Strikes and Initial Proceedings
- First Strike (March 3–12, 1997): held by TEU, declared legal by NLRC; return-to-work order issued March 10, 1997.
- Second Strike (October 17, 1997): declared illegal by NLRC; 23 participants deemed to have lost employment.
- Retrenchment and Transfer of Assets
- Retrenchment notices dated September 16, 1997 were issued to some employees, including respondents, effective 30 days later.
- On December 12, 1997 Times’ Certificates of Public Convenience and bus units were sold to Mencorp Transport Systems, Inc., controlled by the daughter and relatives of Times’ majority stockholder.
- Labor Arbiter and NLRC Decisions
- NLRC Decision May 21, 1998: upheld first strike as legal, second strike as illegal, and denied TEU’s motion to implead Mencorp.
- CA affirmed NLRC Decision on November 17, 2000; SC petition (G.R. 148500-01) pending.
- Unfair Labor Practice Cases and Labor Arbiter Ruling
- Respondents filed illegal dismissal and unfair labor practice complaints before the NCR Arbitration Branch.
- Labor Arbiter Renaldo O. Hernandez (Jan 31, 2002) found unfair labor practice, simulated sale in bad faith, ordered reinstatement, back wages, moral and exemplary damages, and attorney’s fees.
- Appeal Bond Disputes and Subsequent NLRC and CA Actions
- Times, Mencorp, and Spouses Mendoza appealed but failed to post full bond; motions to reduce bond were initially denied.
- NLRC finally granted bond reduction August 7, 2002; on September 17, 2002 it vacated and remanded the case.
- CA granted respondents’ certiorari petition and reinstated Labor Arbiter decision on January 30, 2004; motions for reconsideration denied May 24, 2004.
- Petition for Review on Certiorari
- Times, Mencorp, and Spouses Mendoza petitioned before the SC, alleging litis pendencia, improper appeal bond handling, and incorrect piercing of corporate veil.
Issues:
- Whether the principle of litis pendencia barred the respondents’ unfair labor practice case by virtue of the pending G.R. 148500-01.
- Whether petitioners properly perfected their appeals to the NLRC by posting the required appeal bonds within the reglementary period.
- Whether the corporate veil of Mencorp and the Spouses Mendoza should be pierced to hold them liable for Times’ obligations.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)