Case Summary (G.R. No. 141926)
Background of the Case
On July 17, 1989, Timbal, Jr. and Valenciano received a letter from Tan, instructing them to explain allegations that NSC was not remitting SSS premiums for its employees. Following their explanations, both were indefinitely suspended without due process after being barred from entering the workplace. Consequently, they filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC) on August 3, 1989, which was docketed as NLRC Case No. NCR-00-08-03596-89.
Labor Arbiter's Decision
The Labor Arbiter, Cornelio L. Linsangan, ruled on August 9, 1990, in favor of Timbal, Jr. and Valenciano, finding NSC guilty of illegal dismissal. The ruling mandated the reinstatement of the complainants and the payment of full backwages. Importantly, the Arbiter determined that allegations against Timbal, Jr. and Valenciano regarding false charges against NSC were unsubstantiated, as the SSS had investigated NSC, not the employees.
Execution of the Arbiter's Decision
On October 10, 1990, a Writ of Execution was issued for the reinstatement of the complainants and collection of backwages. However, when attempts were made to enforce this through garnishment, NSC failed to respond adequately, leading Timbal, Jr. and Valenciano to file a motion for separation pay and a new alias writ of execution against NSC and its officers due to unpaid capital subscriptions.
NLRC's Ruling on Alias Writ of Execution
After operating under a series of motions and orders, including a refusal from the labor arbiter to set aside the alias writ of execution, Tan and another stockholder, William Ang, appealed to the NLRC. On June 18, 1997, the NLRC set aside the alias writ of execution on the grounds that Tan and Ang had not been included as party respondents in the original NLRC case and emphasized that stockholders are not automatically liable for corporate debts unless a separate claim is filed against them.
Court of Appeals Proceedings
Timbal, Jr. subsequently filed a petition for certiorari, claiming that the NLRC erred in its decision, which was later referred to the Court of Appeals under Rule 65. On September 24, 1999, the Court of Appeals affirmed the NLRC’s decision for all but Conrado Tan, whose liability was reinstated due to findings of bad faith in the suspension matter.
Supreme Court Decision
Upon further review of the case, the Supreme Court identified a key issue: whether Tan was liable, both jointly and severally, with NSC for the monetary awards in favor of the responde
...continue readingCase Syllabus (G.R. No. 141926)
Case Background
- This case involves a petition for review on certiorari from the Decision of the Court of Appeals in CA-G.R. SP No. 51404.
- The case traces its origins to complaints filed by Restituto Timbal, Jr. and Ernesto Valenciano against Nationwide Steel Corporation (NSC) for illegal dismissal.
- The complainants alleged that they were suspended indefinitely by NSC's general manager, Conrado Tan, after they filed a complaint with the Social Security System (SSS) regarding NSC's failure to remit SSS premiums.
Proceedings Initiated by Complainants
- On July 17, 1989, the complainants received a letter from Tan, requiring them to explain their allegations against NSC within 24 hours.
- Following their submission, they were instructed to report for a resolution, but upon arrival, they were barred entry and handed a suspension memorandum.
- Aggrieved by their treatment, Timbal, Jr. and Valenciano filed a complaint on August 3, 1989, claiming illegal dismissal.
Labor Arbiter's Decision
- The Labor Arbiter ruled on August 9, 1990, in favor of the complainants, ordering NSC to reinstate them and to pay their backwages and benefits.
- The decision indicated that NSC failed to prove the allegations of falsehood against the complainants regarding the SSS contributions, citing a clearance from an SSS legal officer.
Execution of the Arbiter's Decision
- A Writ of Execution was issued on October 10, 1990, to enforce the Labor Arbiter's decision, but NSC did not comply, leading to further legal actions by the complainants.
- An omnibus motion from the complainants req