Case Summary (G.R. No. 210032)
Petition for Review on Certiorari
- The case involves a Petition for Review on Certiorari challenging the Court of Appeals' decision that reversed prior resolutions of the National Labor Relations Commission (NLRC).
- The petitioners are Dutch Movers, Inc. (DMI) and its owners, Cesar Lee and Yolanda Lee, while the respondents are former employees Edilberto Lequin, Christopher R. Salvador, Reynaldo L. Singsing, and Raffy B. Mascardo.
- The Court of Appeals' decision was issued on July 1, 2013, and it also denied a subsequent Motion for Reconsideration on November 13, 2013.
Factual Antecedents
- The respondents filed a complaint for illegal dismissal against DMI and its owners, claiming they were terminated without cause when DMI ceased operations.
- The Labor Arbiter initially dismissed the case for lack of cause of action, but the NLRC later reversed this decision, ruling that the respondents were illegally dismissed.
- The NLRC ordered DMI to reinstate the respondents and pay their back wages, which became final and executory on December 30, 2007.
Motion for Writ of Execution
- After the NLRC decision, the respondents filed a Motion for Writ of Execution, asserting that DMI had ceased operations and that the petitioners were still managing another business, Toyota Alabang.
- The respondents alleged that the incorporation of DMI involved fraud, allowing the petitioners to evade their legal obligations.
- The spouses Smith, who were named in DMI's Articles of Incorporation, claimed they were merely nominal incorporators and had no involvement in DMI's management.
Labor Arbiter's Ruling
- On April 1, 2009, the Labor Arbiter held the petitioners liable for the judgment awards, stating they represented themselves as the owners of DMI.
- The petitioners' motion to quash the Writ of Execution was denied, leading them to appeal to the NLRC.
NLRC's Ruling
- The NLRC quashed the Writ of Execution regarding the petitioners, stating they could not be held personally liable for DMI's obligations.
- The NLRC emphasized that DMI had a separate legal personality and that there was no evidence of bad faith on the part of the petitioners.
Court of Appeals' Ruling
- The Court of Appeals reversed the NLRC's decision, holding that the petitioners were liable for the judgment awards based on their involvement in DMI.
- The CA noted that the petitioners were identified as the individuals who hired the respondents and were involved in DMI's operations.
Petitioners' Arguments
- The petitioners contended that the CA erred in its ruling, arguing that the cases cited by the CA were not applicable and that there was no legal basis to pierce the corporate veil of DMI.
- They maintained that the NLRC's decision was final and executory, and that they had not acted in bad faith.
Respondents' Counterarguments
- The respondents argued that the petitioners were indeed the owners and managers of DMI and should be held liable for the judgment awards.
- They asserted that the petitioners had been consistently impleaded in the case and had the opportunity to defend themselves.
Issue of Personal Liability
- The central issue was whether the petitioners could be held personally liable for the judgment awards in favor of the respondents.
Court's Ruling
- The Court denied the petition, affirming the CA's decision and emphasizing that the principle of immutability of judgment is not absolute.
- The Court found that supervening events, such as DMI's closure, justified the CA's ruling to hold the petitioners personally liable.
Piercing the Corporate Veil
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