G.R. No. 159119 - Uy vs. Bueno

Countrywide Rural Bank of La Carlota, Inc. is a private banking corporation licensed to engage in rural banking operations with a nationwide network of branches.
In April 1998, the bank experienced liquidity problems that spurred a group of depositors to organize and form a committee to safeguard their investments.
The committee elected the following officers:

On January 18, 1999, during a meeting at the Marbel Branch attended by the depositors (not the organizing committee), respondent Amalia A. Bueno announced her termination as Branch Manager.
The meeting was presided over by Marlon V. Juesna, Vice-Chairman of the Bank’s Board.
Petitioners, including Atty. Andrea Uy, were present and confirmed the termination without elaborating on its basis, citing internal issues that could not be discussed publicly.

The day following the meeting (January 19, 1999), respondent Bueno filed a complaint for illegal dismissal before the Labor Arbiter of the NLRC in General Santos City.
The complaint sought reinstatement, full back wages, damages, and attorney’s fees.
Petitioners Uy and Yusay were sued in their capacities as Interim President/Corporate Secretary and Interim Board Chairman, respectively, while other bank officials were also named.

The Labor Arbiter found that respondent Bueno was dismissed verbally and summarily without valid cause, in violation of Article 277(b) of the Labor Code, and that she was protected by the security of tenure provision (Article 279).
The Arbiter awarded separation pay in lieu of reinstatement, back wages, moral and exemplary damages, and attorney’s fees (10%) as compensation for the manner of dismissal.
On September 28, 1999, respondent Bueno filed a Manifestation for early resolution, asserting that the Bank was under receivership by the PDIC.
On November 18, 1999, a decision was rendered in her favor based solely on her submitted position paper.

On May 24, 2000, petitioner Uy filed a Notice and Memorandum of Appeal before the Fifth Division of the NLRC, contesting the Labor Arbiter’s decision on due process and evidentiary grounds.
The NLRC dismissed the appeal on July 31, 2000, ruling it as filed out of time, thus rendering the original decision final and executory.
On August 28, 2000, petitioners Uy and Yusay filed a Motion for Reconsideration alleging non-service of the decision and that they had received the decision only on May 9, 2000.
The NLRC granted the Motion on December 21, 2001, reversing the decision insofar as it implicated petitioner Uy personally, based on evidence that they were merely depositors turned interim officers via the depositors’ meeting.

On February 8, 2002, respondent Bueno filed a Motion for Reconsideration against the NLRC’s decision, which was denied on March 22, 2002.
Respondent Bueno then appealed to the Court of Appeals (CA), raising issues including:

The CA, in its decision dated January 24, 2003, ruled in favor of respondent Bueno by:

Petitioners subsequently filed a Motion for Reconsideration on February 12, 2003, which was denied by the CA on May 26, 2003.

The entire litigation centered on whether petitioner Uy, acting in her capacity allegedly as an officer, could be held solidarily liable with the Bank in the illegal dismissal of respondent Bueno.
Discrepancies were evident in the findings:

The Labor Arbiter and initial NLRC decisions held Uy liable and treated her as an officer.
The NLRC later absolved Uy based on evidence showing that she was merely a depositor who was elected as an interim officer.
The CA ultimately reversed the NLRC’s later decision, re-establishing Uy’s status as an officer and her liability.

Whether or not the Court of Appeals erred in finding that the NLRC gravely abused its discretion, amounting to lack or in excess of jurisdiction in issuing the resolutions dated December 21, 2001, and March 22, 2002.
Whether or not the Court of Appeals erred in affirming that summons was properly served on petitioners, particularly petitioner Uy.
Whether or not the Court of Appeals erred in finding that petitioners are officers of the Bank based on their admissions and the evidence presented.
Whether or not the Court of Appeals erred in ruling that the dismissal of respondent Bueno was carried out in bad faith and with malice.
Whether or not petitioners, as corporate officers, should be held solidarily liable with Countrywide Rural Bank for respondent Bueno’s illegal dismissal.