Case Digest (G.R. No. 212774) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In WESLEYAN UNIVERSITY-PHILIPPINES v. GUILLERMO T. MAGLAYA, SR., petitioner Wesleyan University–Philippines (WUP), a non-stock, non-profit, non-sectarian educational corporation organized on April 28, 1948, appointed Guillermo T. Maglaya, Sr. as corporate member on January 1, 2004 and trustee on January 9, 2004 for five-year terms, and elected him President on May 25, 2005 for another five years. He was re-elected trustee on May 25, 2007. On November 28, 2008, the United Methodist Church Bishops notified corporate members that their terms would expire on December 31, 2008 unless renewed. Although Maglaya sought renewal, the Board’s chairman informed the Bishops that vacancies could only be filled upon the Board’s recommendation. On March 25, 2009 Maglaya learned that the Bishops had formed an ad hoc committee and appointed new corporate members and trustees, which was formalized by notice on April 24, 2009 announcing that the new Board had organized and elected officers on April Case Digest (G.R. No. 212774) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Appointments
- Wesleyan University-Philippines (WUP) is a non–stock, non–profit, non-sectarian educational corporation organized on April 28, 1948.
- Respondent Guillermo T. Maglaya, Sr. was appointed corporate member (January 1, 2004), elected trustee (January 9, 2004; re-elected May 25, 2007), and elected University President for a five-year term on May 25, 2005.
- Expiration of Terms and New Board Installation
- By memorandum dated November 28, 2008, the Bishops of the United Methodist Church advised that corporate terms expired December 31, 2008 unless renewed. Maglaya and other members sought renewal.
- Bishops formed an Ad Hoc Committee, appointed new corporate members and trustees (formal notice April 24, 2009), and new Board Chairman Palomo terminated Maglaya’s presidency on April 27, 2009.
- Procedural History
- Maglaya and former board members filed an injunction and damages suit in the RTC; it was dismissed as a prohibited intra-corporate harassment suit; CA affirmed (2011).
- Maglaya filed an illegal dismissal complaint with the Labor Arbiter (LA); LA dismissed for lack of jurisdiction (2011); NLRC reversed, finding illegal dismissal and awarding P2,505,208.75 (2012); CA denied WUP’s Rule 65 petition; WUP elevated to the Supreme Court.
Issues:
- Whether respondent Maglaya is a corporate officer or a mere employee for purposes of jurisdiction.
- Whether the NLRC had jurisdiction over his illegal dismissal case.
- Whether WUP timely availed of its remedy to assail the NLRC decision by certiorari under Rule 65.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)