Case Summary (G.R. No. 196036)
Procedural Background
On December 14, 1993, the respondents filed separate complaints for illegal dismissal against the placement agency PRO Agency Manila, Inc. After hearings, the Labor Arbiter rendered a decision on May 7, 1997, ordering the agency and Al Mahwes to pay the respondents various claims. Following unsatisfactory attempts at execution, in 2002, the respondents successfully moved to implead Gagui as a judgment debtor, despite her being neither a party to the original complaint nor named in the decision.
Implementing Liability Claims
The Executive Labor Arbiter granted the motion to implead Gagui and subsequently issued various alias writs of execution to collect on the judgment, leading to the garnishment of Gagui’s bank deposit and the levying of her properties. Gagui contested her liability by arguing that the 1997 decision did not name her as liable and claimed that implementing her liability violated the final and executory nature of the decision.
Labor Arbiter's Orders and NLRC Ruling
The Labor Arbiter denied Gagui’s motions to quash the writs and affirmed that corporate officers could be held jointly and severally liable under R.A. 8042. Gagui appealed to the National Labor Relations Commission (NLRC), which upheld the Labor Arbiter’s orders and clarified that individual corporate officers do not need to be impleaded for liability to attach if they are found liable under the law.
Court of Appeals Decision
The Court of Appeals (CA) also affirmed the NLRC’s ruling, indicating that Gagui was solidarily liable under the provisions of R.A. 8042 without being explicitly named in the original decision. The CA reinforced the interpretation that corporate officers can be held liable under the Act without specific prior mention in the judgment to enforce a claim against them.
Rule on Timeliness of the Petition
Gagui subsequently filed a petition for review, which was questioned by the respondents on timeliness. However, the Supreme Court ruled that Gagui had a fresh 15-day period to file her petition after receiving the CA's resolution denying her motions for reconsideration, as established in previous jurisprudence, specifically the Neypes rule.
Ruling on Joint and Several Liability
The Supreme Court further evaluated the merits of Gagui's claimed liability under R.A. 8042. The Court emphasized that while the Act allows for liability of corporate officers for the actions of their corporation, this liability is not automatic. The Court determined that there was no evidence presented that in
...continue readingCase Syllabus (G.R. No. 196036)
Case Background
- This case involves a Rule 45 Petition dated 30 March 2011 challenging the Decision and Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 104292.
- The CA affirmed the National Labor Relations Commission (NLRC) Decision in NLRC Case No. OCW-RAB-IV-4-392-96-RI, which found petitioner Elizabeth M. Gagui solidarily liable alongside PRO Agency Manila, Inc. for respondents' claims due to their illegal dismissal.
- Respondents Simeon Dejero and Teodoro Permejo initially filed separate complaints on 14 December 1993 for illegal dismissal and other related claims against PRO Agency Manila, Inc. and Abdul Rahman Al Mahwes.
Labor Arbiter's Decision
- On 7 May 1997, Labor Arbiter Pedro Ramos rendered a decision ordering joint and several payments from the respondents and the placement agency, totaling various claims, including:
- Unpaid salaries from July 1992 to September 1993.
- Overtime pay for fourteen months.
- Refund of plane tickets.
- Refund of excessive placement fees.
- Moral and exemplary damages.
- Attorney’s fees.
- A Writ of Execution was issued on 10 October 1997, but it was returned unsatisfied, leading to subsequent alias writs.
Impleading of Corporate Officers
- On 30 October 2002, respondents filed a motion to implead corporate officers of PRO Agency, including Gagui, as judgment debtors.
- Executive Labor Arbiter Voltaire A. Balitaan issued an order on 25 April 2003 granting the motion, holding Gagui jointly and solidarily