Wesleyan University-Philippines v. Maglaya
REITERATIONFacts
The Antecedents: Respondent Atty. Guillermo T. Maglaya, Sr. was appointed as a corporate member and elected as a member of the Board of Trustees of petitioner Wesleyan University-Philippines (WUP) for five-year terms, and subsequently elected as President of the University. The terms of some corporate members, including Maglaya, expired on December 31, 2008. WUP appointed new corporate members and trustees, and Maglaya was informed of the termination of his services as President. Procedural History: Maglaya and other former Board members filed a complaint for injunction and damages before the RTC, which dismissed the case as a nuisance or harassment suit, ruling that the expiration of their terms as corporate members terminated their positions on the Board. The CA affirmed the RTC's decision. Maglaya then filed an illegal dismissal case against WUP before the labor tribunals. The Labor Arbiter dismissed the case for lack of jurisdiction, finding Maglaya to be a corporate officer. The NLRC reversed this, ruling that Maglaya was an employee and illegally dismissed, awarding him significant damages. WUP filed a petition for certiorari before the CA, which dismissed it for being filed out of time and for lack of merit. The Petition: WUP filed a petition for review on certiorari before the Supreme Court, assailing the CA's dismissal of its petition for certiorari, arguing that the NLRC had no jurisdiction over the case involving a corporate officer and that the CA erred in summarily dismissing its petition.
Issue(s)
Whether the Court of Appeals committed an error of law when it summarily dismissed the special civil action for certiorari raising lack of jurisdiction of the NLRC. Whether the NLRC has jurisdiction over the illegal dismissal case filed by Maglaya, which hinges on whether Maglaya is a corporate officer or a mere employee.
Ruling
The Supreme Court granted the petition, reversed and set aside the assailed Resolution of the Court of Appeals, and ordered respondent Atty. Guillermo T. Maglaya, Sr. to reimburse petitioner the amount awarded by the National Labor Relations Commission. The Court held that the NLRC erred in assuming jurisdiction over the case, as the subject matter is an intra-corporate controversy falling under the jurisdiction of the regular courts.
Ratio Decidendi
On the jurisdiction of the Court of Appeals over the NLRC decision: The Court reiterated that while NLRC decisions become final and executory, they can still be assailed via a Petition for Certiorari under Rule 65 before the CA on jurisdictional and due process considerations, provided it is filed within the reglementary period. The Court found that WUP complied with the necessary conditions, including filing a motion for reconsideration and then filing the petition for certiorari within the prescribed period. Therefore, the CA erred in dismissing the petition solely on the ground of finality of the NLRC decision. On whether the NLRC has jurisdiction over the illegal dismissal case: The Court held that the NLRC erred in taking cognizance of the case. The determination of whether an individual is a corporate officer or a mere employee is crucial for establishing jurisdiction. Corporate officers are those given that character by the Corporation Code or the corporation's by-laws. The President of WUP, as defined in its by-laws, is an officer of the corporation, not a mere employee. The by-laws clearly outline the creation of the position and the manner of appointment or election, which are hallmarks of a corporate officer. The Court emphasized that a corporate officer's dismissal is always a corporate act or an intra-corporate controversy, which falls under the exclusive jurisdiction of the Regional Trial Courts, as provided by Section 5(c) of PD 902-A, as amended by RA 8799. The NLRC's finding that Maglaya was a mere employee based on the manner of his appointment, duties, salaries, and allowances was contrary to the established definition of a corporate officer as provided in the by-laws. Therefore, the NLRC lacked jurisdiction over the subject matter of the complaint.
Main Doctrine
The dismissal of a corporate officer is an intra-corporate controversy falling within the exclusive jurisdiction of the Regional Trial Courts, not the labor tribunals, regardless of the reason for dismissal.