Title
Sara Lee Philippines, Inc. vs. Macatlang
Case
G.R. No. 180147
Decision Date
Jan 14, 2015
Aris Philippines' closure led to 5,984 employees filing illegal dismissal claims against FAPI and associated corporations. Labor Arbiter awarded P3.4B; appeal bond issues and premature NLRC resolution ensued. SC upheld P725M bond, denied compromise, and ordered NLRC to resolve merits.

Case Summary (G.R. No. 180147)

Applicable Law

The case is governed by provisions of the 1987 Philippine Constitution and the Labor Code of the Philippines.

Decision Summary

The Supreme Court addressed a Motion for Reconsideration concerning a previous decision from June 4, 2014, which directed the petitioners to post a bond of P725 Million, and declared the National Labor Relations Commission (NLRC) Resolution from December 19, 2006, as premature.

Grounds for Reconsideration

The petitioners contended that the Court had failed to acknowledge several significant legal violations, including:

  • Jurisdictional issues concerning due process rights due to non-inclusion and non-service of summons to SLPI, SLC, and Cruz.
  • Lack of employer-employee relationships.
  • Legal impediments to the NLRC's authority to vacate the Labor Arbiter's decision without a Temporary Restraining Order (TRO).
  • Prescriptive periods for filing money claims as stated under Article 291 of the Labor Code and the doctrine of res judicata due to prior final decisions on similar issues.

Factual Background

In the initial ruling, a Labor Arbiter found that the dismissals were illegal and awarded substantial monetary compensation of over P3.4 billion. The Corporations appealed, and the NLRC eventually reduced the amount of the required appeal bond, despite the complexities of the case and multiple legal issues being raised throughout the process.

Issues on Appeal and Decisional Elements

The Court rejected the petitioners' claims for reconsideration, emphasizing the validity of the bond requirement and the requirements necessary for a proper appeal under the NLRC's guidelines. The Court found the petitioners' arguments lacking merit, stressing that any failure to properly post bonds or comply with procedural requirements would not invalidate the binding nature of the prior judgments made by labor arbiters.

Confession of Judgment

The petitioners attempted to introduce a Confession of Judgment with a substantially lower monetary offer to settle claims, which was found to represent only a small fraction of the original award. The Court criticized this move as potentially undermining the legal rights of the respondents since it failed to reflect an equitable settlement.

Conclus

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