Chua v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: City Air International Brokerage Corporation, a family corporation, employed Jesus G. Chua as its president from October 1984 until his resignation in March 1985. Johnson G. Chua served as the corporation's vice-president during the same period. Jesus G. Chua filed a complaint against the corporation and Johnson G. Chua for illegal dismissal and recovery of unpaid wages amounting to P29,250.00 for the period of November 15, 1984, to March 31, 1985. 2. Procedural History: The Labor Arbiter ruled in favor of Jesus G. Chua, ordering City Air International Corporation and/or Johnson Chua to pay the unpaid wages. This decision was affirmed by the National Labor Relations Commission (NLRC) on June 30, 1987. A subsequent motion for reconsideration filed by Johnson Chua was denied by the NLRC on December 7, 1987. 3. The Petition: Johnson G. Chua filed a petition with the Supreme Court, arguing that he, as vice-president, should not be held jointly and severally liable with the corporation for the unpaid wages of the former president, citing the separate legal personality of corporations. The Supreme Court, referencing the precedent set in A.C. Ransom Labor Union-CCLU v. National Labor Relations Commission, considered the specific circumstances, including the familial relationship between the parties, Johnson Chua's personal interest and actions in defending the case despite his brother's resignation and the election of a new president, and the existence of personal animosity, to uphold the NLRC's decision holding the vice-president liable under Article 289 of the Labor Code.
Issue(s)
Whether the vice-president can be held jointly and severally liable with the corporation for the unpaid wages of the former president. Whether the findings of fact of the NLRC are supported by substantial evidence.
Ruling
The petition is dismissed, and the questioned decision of the National Labor Relations Commission is affirmed. The vice-president, Johnson Chua, is held jointly and severally liable with the corporation for the unpaid wages of the former president, Jesus Chua.
Ratio Decidendi
On whether the vice-president can be held jointly and severally liable with the corporation for the unpaid wages of the former president: The Court applied the precedent set in A.C. Ransom Labor Union-CCLU v. National Labor Relations Commission, which held that corporate officers acting in the interest of the employer can be held personally liable for corporate obligations to workers. The definition of 'employer' under the Labor Code includes 'any person acting in the interest of an employer directly or indirectly.' In this case, the petitioner, as vice-president and the highest-ranking official after the private respondent's resignation, demonstrated personal interest and involvement in the case, even verifying pleadings and motions. This personal involvement, coupled with the existence of personal animosity between the brothers, led the Court to believe the petitioner had a hand in the dismissal and non-payment of wages. Article 289 of the Labor Code further supports that if an offense is committed by a corporation, the penalty shall be imposed upon the guilty officer or officers. On whether the findings of fact of the NLRC are supported by substantial evidence: The Court reiterated the general rule that findings of fact of quasi-judicial agencies like the NLRC, which have acquired expertise, are accorded respect and even finality if supported by substantial evidence. In this case, the Labor Arbiter found that the private respondent was entitled to his unpaid wages, a finding confirmed by an independent certified public accountant. The petitioner's personal interest and actions in handling the case, despite a new president being elected, constituted substantial evidence supporting the NLRC's decision. The Court found no reversible error in the NLRC's application of the law based on these factual findings.
Main Doctrine
A corporate officer, such as a vice-president, can be held jointly and severally liable with the corporation for unpaid wages, especially when the officer acted in the interest of the employer and demonstrated personal interest and involvement in the case, despite the general rule of separate corporate personality.