Case Summary (G.R. No. 200094)
Antecedents
The Philippine College of Criminology Inc. (PCCr) is a non-stock educational institution employing the petitioners as maintenance personnel. The petitioners were misled into believing they were employed by Metropolitan Building Services, Inc. (MBMSI), a company providing janitorial services, which was later discovered to have had its Certificate of Incorporation revoked in 2003. In 2009, PCCr terminated its relationship with MBMSI due to this revocation, leading to the dismissal of the petitioners. They subsequently filed complaints for illegal dismissal against MBMSI, PCCr, and Bautista.
Labor Arbiter's Ruling
The Labor Arbiter (LA) rendered a decision confirming that PCCr was the real employer, classifying MBMSI as a labor-only contractor. The LA ordered PCCr to reinstate the petitioners and pay various compensations, including back wages and moral damages. The LA noted that others, including Atty. Florante A. Seril, had acted on behalf of PCCr, furthering subordination.
NLRC Resolutions
Upon appealing to the National Labor Relations Commission (NLRC), the respondents were partially vindicated as the NLRC acknowledged the releases, waivers, and quitclaims signed by the petitioners in favor of MBMSI. Consequently, the NLRC held that the petitioners’ claims were settled, thus absolving MBMSI and Atty. Seril from liability.
Court of Appeals' Decision
The Court of Appeals (CA) upheld the NLRC’s findings, emphasizing the validity of the releases, waivers, and quitclaims executed by the petitioners. It noted that the petitioners failed to adequately challenge these documents and substantiated their authenticity.
Grounds for Petition
The petitioners challenged the CA's affirmation of the NLRC’s decisions on several grounds, primarily arguing that there was no legal basis for considering MBMSI’s liability as solidary with PCCr and that the releases extinguished their claims against the respondents.
Court’s Analysis: Validity of Releases
The Court rejected claims of forgery related to the releases, waivers, and quitclaims, as they were duly notarized documents whose genuineness had not been adequately challenged during earlier proceedings. The petitioners’ later denial of execution was dismissed as an afterthought. The Court further emphasized that the rules on notarized documents presume authenticity unless proven otherwise.
Revocation of MBMSI’s Certificate of Incorporation
The Court addressed petitioners’ arguments concerning MBMSI’s lack of legal capacity due to its revoked incorporation. It cited that despite the revocation, the executed releases and quitclaims remained valid owing to the Corporation Code, allowing for a three-year period post-revocation for settling affa
...continue readingCase Syllabus (G.R. No. 200094)
Case Information
- Citation: 710 Phil. 809
- Division: Third Division
- G.R. No.: 200094
- Date of Decision: June 10, 2013
- Petitioners: Benigno M. Vigilla, Alfonso M. Bongot, Roberto Callesa, Linda C. Callo, Nilo B. Camara, Adelia T. Camara, Adolfo G. Pinon, John A. Fernandez, Federico A. Callo, Maxima P. Arellano, Julito B. Costales, Samson F. Bachar, Edwin P. Damo, Renato E. Fernandez, Genaro F. Callo, Jimmy C. Aleta, and Eugenio Salinas
- Respondents: Philippine College of Criminology, Inc. and/or Gregory Alan F. Bautista
Procedural History
- The petition for review on certiorari under Rule 45 contests the September 16, 2011 Decision of the Court of Appeals (CA) which affirmed the February 11, 2011 and the April 28, 2011 Resolutions of the National Labor Relations Commission (NLRC).
- The NLRC's resolutions modified the July 30, 2010 Decision of the Labor Arbiter (LA), which had ruled that Metropolitan Building Services, Inc. (MBMSI) was a labor-only contractor, that PCCr was the real employer, and that PCCr acted in bad faith in dismissing the petitioners.
Antecedents
- PCCr is a non-stock educational institution supervising janitorial staff, who were allegedly employed by MBMSI, a corporation providing janitorial services.
- In 2008, PCCr discovered that MBMSI's Certificate of Incorporation had been revoked since July 2, 2003, leading to termination of its relationship with MBMSI in March 2009.
- Dismissed employees, led by Benigno Vigilla, filed complaints for illegal dismissal and various forms of compensation against MBMSI, Atty. Seril (PCCr's Senior Vice President), and PCCr.
Labor Arbiter's Ruling
- The LA ruled that PCCr was the principal employer and MBMSI was a mere labor-only contractor.
- Findings included:
- The complainants were regular employees of PCCr.
- PCCr acted in bad faith during the dismissal.
- The LA ordered reinstatement and compensation, totaling P2,963,584.25 for back wages, separation pay, service incentive leave, moral and exemplary damages, and at