Case Digest (G.R. No. 157900) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Zuellig Freight and Cargo Systems, Inc. v. National Labor Relations Commission and Ronaldo V. San Miguel, petitioner Zuellig Freight and Cargo Systems, Inc., formerly Zeta Brokerage Corporation, challenges the November 6, 2002 decision of the Court of Appeals affirming the National Labor Relations Commission’s (NLRC) April 4, 2001 resolution that respondent Ronaldo V. San Miguel was illegally dismissed. San Miguel, a checker/customs representative, was hired by Zeta on December 16, 1985. In January 1994, Zeta announced it would cease operations and by letter dated February 28, 1994 informed San Miguel of his termination effective March 31, 1994. San Miguel accepted separation pay under a standing offer to be rehired by Zeta’s corporate successor, petitioner Zuellig, which had amended its articles of incorporation on January 21, 1994 merely to change its corporate name, broaden its purpose, and increase capital stock. He resumed work on April 1, 1994 but was summarily terminat Case Digest (G.R. No. 157900) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Ronaldo V. San Miguel was employed as a checker/customs representative by Zeta Brokerage Corporation since December 16, 1985.
- In January 1994, Zeta informed its employees of an impending cessation of operations and issued a termination letter dated February 28, 1994, effective March 31, 1994; San Miguel accepted separation pay subject to a standing offer of re-employment by the successor entity.
- Corporate Amendments and Employment Events
- Zeta amended its Articles of Incorporation on January 21, 1994 (filed with the SEC) and its By-Laws on May 10, 1994, to change its corporate name to Zuellig Freight and Cargo Systems, Inc., broaden its purposes, and increase its authorized capital stock.
- On April 1, 1994, San Miguel was rehired on a temporary basis by the renamed corporation and was summarily terminated on April 15, 1994 without valid cause or due process.
- Procedural History
- San Miguel filed a complaint for unfair labor practice, illegal dismissal, non-payment of salaries, and moral damages before the Labor Arbiter. On November 15, 1999, the Arbiter ruled his dismissal illegal, ordering backwages (April 1, 1994 to November 15, 1999) and attorney’s fees.
- The NLRC affirmed via resolutions dated April 4, 2001 and June 15, 2001. The Court of Appeals dismissed Zuellig’s certiorari petition on November 6, 2002. Zuellig then filed a petition for review on certiorari with the Supreme Court.
Issues:
- Whether the corporate name change and amendments constituted a bona fide cessation of business under Article 283 of the Labor Code.
- Whether the NLRC and the Court of Appeals gravely abused their discretion in declaring San Miguel’s dismissal illegal.
- Whether the award of attorney’s fees to San Miguel was proper under applicable law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)