Case Summary (G.R. No. 193136)

Petition Overview

• The case involves a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
• The petitioner, ABS-CBN Broadcasting Corporation, challenges the Decision and Resolution of the Court of Appeals (CA) which held it jointly and severally liable with Creative Creatures, Inc. (CCI) for the illegal dismissal of respondents Honorato C. Hilario and Dindo B. Banting.
• The CA partially granted the petition, ordering deductions from the monetary award based on quitclaims executed by the respondents.

Background of the Parties

• ABS-CBN is a domestic corporation engaged in broadcasting, initially managing its own Scenic Department for set design and props.
• CCI was formed in 1995 by Edmund Ty and several ABS-CBN officers to provide similar services after the Scenic Department was abolished.
• Respondent Hilario was hired by CCI in 1995 and rose to Set Controller, while Banting joined in 1999 and became Assistant Set Controller.

Closure of CCI

• In June 2003, Ty retired from CCI and entered a consultancy agreement with ABS-CBN.
• CCI's Board decided to cease operations due to financial difficulties, with a corporate term shortened to October 31, 2003.
• Employees, including respondents, were notified of their termination effective October 5, 2003, and received separation pay.

Legal Proceedings Initiated by Respondents

• Respondents filed a complaint for illegal dismissal and other claims against CCI and ABS-CBN before the National Labor Relations Commission (NLRC).
• They argued that the closure was a bad faith maneuver to circumvent labor laws, as CCI continued operations under the guise of a new company, Dream Weaver Visual Exponents, Inc. (DWVEI).

Labor Arbiter's Ruling

• The Labor Arbiter found respondents illegally dismissed and ordered their reinstatement with full backwages.
• The ruling emphasized that CCI's closure was a circumvention of labor laws, and both CCI and ABS-CBN were jointly liable.

NLRC Decision

• The NLRC affirmed the Labor Arbiter's decision, reiterating that CCI and ABS-CBN should be treated as a single entity due to the latter's control over CCI.
• The NLRC dismissed the appeal of the respondents and ordered their reinstatement.

Court of Appeals Ruling

• The CA upheld the finding of illegal dismissal but modified the NLRC's decision regarding the monetary award, allowing deductions for quitclaims.
• Petitioner filed a motion for reconsideration, which was denied.

Issues Raised by Petitioner

• Petitioner contended that there was no basis to disregard the separate corporate personalities of ABS-CBN and CCI.
• It argued that the termination was valid and that reinstatement was impossible due to the non-existence of relevant positions.

Respondents' Counterarguments

• Respondents claimed that CCI's closure was a pretext to evade labor laws and that it continued operations under DWVEI.
• They argued that the corporate structure was manipulated to disadvantage employees.

Supreme Court's Ruling

• The Court affirmed the findings of the lower tribunals, emphasizing that the closure of CCI was not bona fide and was intended to circumvent labor protections.
• The Court applied the doctrine of piercing the corporate veil, treating CCI and A...continue reading

Case Syllabus (G.R. No. 193136)

Overview of the Case

• The case is a petition for review on certiorari filed under Rule 45 of the 1997 Rules of Civil Procedure.
• The petitioner is ABS-CBN Broadcasting Corporation (ABS-CBN), while the respondents are Honorato C. Hilario and Dindo B. Banting, who were illegally dismissed from their employment with Creative Creatures, Inc. (CCI).
• The Court of Appeals (CA) held ABS-CBN jointly and severally liable with CCI for the illegal dismissal of the respondents, but also ordered the deduction of amounts received by the respondents through quitclaims from their monetary awards.

Background of the Parties

• ABS-CBN is a domestic corporation engaged in broadcasting television and radio content.
• CCI was incorporated in 1995 by Mr. Edmund Ty and several ABS-CBN officers, initially handling set design and props for ABS-CBN shows.
• Respondent Honorato was employed by CCI from March 6, 1995, and rose to the position of Set Controller. Respondent Banting began working as a Metal Craftsman in April 1999 and became Assistant Set Controller.

Events Leading to Termination

• Ty retired in June 2003, leading to financial struggles for CCI, which prompted its Board of Directors to decide to close the company effective October 31, 2003.
• Respondents were served termination notices on September 4 and 5, 2003, informing them of the cessation of operations of CCI.
• Upon termination, both respondents received separation pay and executed quitclaims in favor of CCI.

Legal Proceedings Initiated by Respondents

• Respondents filed a comp...continue reading