Case Summary (G.R. No. 125793)
Relevant Legal Findings
Following the trial overseen by Presiding Judge Jose S. Bautista, a finding was made against Emilio and Rodolfo Cano for engaging in unfair labor practices, while Ariston Cano was exonerated due to a lack of evidence. The court ordered the reinstatement of Honorata Cruz to her former position, alongside the payment of back wages from the time of her dismissal until her reinstatement. Notably, Emilio Cano passed away on November 14, 1958, during the legal proceedings, yet the case continued.
Order of Execution and Legal Challenge
An order of execution was issued on August 23, 1961, mandating the reinstatement of Honorata Cruz and requiring the payment of P7,222.58 within ten days. Failure to comply would result in either a levy on the Cano's properties or contempt proceedings. Emilio Cano Enterprises, Inc. contested this order, arguing that the judgment should not extend to the corporation given its distinct legal personality and that the judgment was not rendered against it directly.
Corporate Liability and Legal Precedents
In determining the validity of the corporation's claims, the court emphasized the principle that while a corporation is legally distinct from its members, this separation does not apply when the members are closely interconnected, as with family corporations. The court highlighted that the incorporators of Emilio Cano Enterprises, Inc. were family members, positioning the corporation and its officials as effectively one entity in the context of the actions leading to the unfair labor practice charge.
Court's Conclusion on Corporate Actions
The court concluded that the actions of Emilio and Rodolfo Cano, performed in their official capacities, could justly render the corporation liable for the resulting obligations. The order for reinstatement and wage payment meant that the obligations were inherently tied to the corporation's responsibilities. Furthermore, remanding the case for a technical substitution of parties would not s
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Case Background
- The case originated from a complaint for unfair labor practice filed on June 6, 1956, by a Prosecutor of the Court of Industrial Relations.
- Respondents included Emilio Cano, Ariston Cano, and Rodolfo Cano, who held positions as president, field supervisor, and manager respectively in Emilio Cano Enterprises, Inc.
- After a trial, Judge Jose S. Bautista found Emilio Cano and Rodolfo Cano guilty of unfair labor practices but absolved Ariston Cano due to insufficient evidence.
Court Decision
- The court ordered Emilio and Rodolfo Cano to reinstate Honorata Cruz and to pay her back wages from the time of her dismissal until her reinstatement, along with all associated rights and privileges.
- Emilio Cano passed away on November 14, 1958. Attempts to dismiss the case against him were unsuccessful.
- The case was appealed to the court en banc, which affirmed Judge Bautista's decision.
Order of Execution
- An order of execution was issued on August 23, 1961, requiring:
- Reinstatement of Honorata Cruz to her former position as per the initial decision.
- A deposit of P7,222.58 with the court within ten days;