This case has been cited 9 times or more.
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2015-08-18 |
VELASCO JR., J. |
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| Admittedly, mere ownership by a single stockholder of all or nearly all of the capital stock of the corporation does not by itself justify piercing the corporate veil. Nonetheless, in this case, other circumstances show that the buyer of the assets of petitioners' employer is none other than his alter ego.[41] We quote with approval the observations of ELA Santos:Respondents did not allege that they informed complainants neither did they state in the notices of termination that the buyer in the "impending sale" is NH Oil Mill. Pondering on these observations, this Office finds it too difficult to surmise that respondents' omission was not deliberate, and so this Office holds that Noel was not in good faith in dealing with complainants. The information disclosed by the Certificate of Registration and Articles of Incorporation of NH Oil Mill explains respondents' motive. Its stockholders are members of [Noel's] family known to complainants, and Noel is the controlling stockholder and director. The immediate resumption of operation after cessation of operation on March 15, 2010 further explains it. While complainants failed to prove that the stockholders in NH Oil Mill were those who managed ANJH, respondents did not dispute that there was no change in the management people, premises, tools, devices, equipment, and machinery under NH Oil Mill. The buyer in the "impending sale" undisclosed in the notices to complainants is divulged by subsequent development to be practically the same as the seller. These things are inconsistent with good faith. | |||||
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2013-10-23 |
REYES, J. |
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| "[S]ettled is the rule that factual findings of labor officials, who are deemed to have acquired expertise in matters within their jurisdiction, are generally accorded not only respect but even finality by the courts when supported by substantial evidence, i.e., the amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion."[31] "The factual findings of the NLRC, when affirmed by the CA, are generally conclusive on this Court."[32] | |||||
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2013-06-19 |
BRION, J. |
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| With respect to Century Iron's assertion that Bañas was grossly and habitually neglectful of his duties, the CA erred in ruling that the NLRC did not commit grave abuse of discretion in concluding that the dismissal was illegal. The NLRC's finding that there was illegal dismissal on the ground of gross and habitual neglect of duties is not supported by the evidence on record. It believed in Bañas' bare and unsubstantiated denial that he was not grossly and habitually neglectful of his duties when the record is replete with pieces of evidence showing the contrary. Consequently, the NLRC capriciously and whimsically exercised its judgment by failing to consider all material evidence presented to it by the petitioners and in giving credence to Bañas' claim which is unsupported by the evidence on record.[39] | |||||
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2013-03-06 |
MENDOZA, J. |
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| Well-settled is the rule that "factual findings of labor officials, who are deemed to have acquired expertise in matters within their jurisdiction, are generally accorded not only respect but even finality by the courts when supported by substantial evidence."[24] Furthermore, the factual findings of the NLRC, when affirmed by the CA, are generally conclusive on this Court.[25] When the petitioner, however, persuasively alleges that there is insufficient or insubstantial evidence on record to support the factual findings of the tribunal or court a quo, then the Court, exceptionally, may review factual issues raised in a petition under Rule 45 in the exercise of its discretionary appellate jurisdiction.[26] | |||||
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2012-10-23 |
BRION, J. |
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| To be sure, if the NLRC's findings had been arrived at arbitrarily or in disregard of the evidence on record, the CA would have been right and could have granted the petition for certiorari on the finding that the NLRC made a factual finding not supported by substantial evidence.[26] The CA, in fact, did not appear to have looked into these matters and did not at all ask whether the NLRC's findings on the awarded monetary benefits were supported by substantial evidence. This omission, however, did not render the NLRC's ruling defective as Jimenez v. NLRC, et al.[27] teaches us that | |||||
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2012-10-10 |
REYES, J. |
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| On this matter, the settled rule is that factual findings of labor officials, who are deemed to have acquired expertise in matters within their jurisdiction, are generally accorded not only respect but even finality by the courts when supported by substantial evidence, i.e., the amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion. We emphasize, nonetheless, that these findings are not infallible. When there is a showing that they were arrived at arbitrarily or in disregard of the evidence on record, they may be examined by the courts. The CA can then grant a petition for certiorari if it finds that the NLRC, in its assailed decision or resolution, has made a factual finding that is not supported by substantial evidence. It is within the jurisdiction of the CA, whose jurisdiction over labor cases has been expanded to review the findings of the NLRC.[47] | |||||
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2012-08-29 |
BERSAMIN, J. |
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| The principle of substantial compliance recognizes that exigencies and situations do occasionally demand some flexibility in the rigid application of the rules of procedure and the laws.[26] That rules of procedure may be mandatory in form and application does not forbid a showing of substantial compliance under justifiable circumstances,[27] because substantial compliance does not equate to a disregard of basic rules. For sure, substantial compliance and strict adherence are not always incompatible and do not always clash in discord. The power of the Court to suspend its own rules or to except any particular case from the operation of the rules whenever the purposes of justice require the suspension cannot be challenged.[28] In the interest of substantial justice, even procedural rules of the most mandatory character in terms of compliance are frequently relaxed. Similarly, the procedural rules should definitely be liberally construed if strict adherence to their letter will result in absurdity and in manifest injustice, or where the merits of a party's cause are apparent and outweigh considerations of non-compliance with certain formal requirements.[29] It is more in accord with justice that a party-litigant is given the fullest opportunity to establish the merits of his claim or defense than for him to lose his life, liberty, honor or property on mere technicalities. Truly, the rules of procedure are intended to promote substantial justice, not to defeat it, and should not be applied in a very rigid and technical sense.[30] Petitioner urges the Court to resolve the apparent conflict between the rulings in Heirs of Pedro Cabais v. Court of Appeals[31] (Cabais) and in Heirs of Ignacio Conti v. Court of Appeals[32] (Conti) establishing filiation through a baptismal certificate.[33] | |||||
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2012-01-18 |
REYES, J. |
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| For the piercing doctrine to apply, it is of no consequence if Sceptre is a sole proprietorship. As ruled in Prince Transport, Inc., et al. v. Garcia, et al.,[55] it is the act of hiding behind the separate and distinct personalities of juridical entities to perpetuate fraud, commit illegal acts, evade one's obligations that the equitable piercing doctrine was formulated to address and prevent: A settled formulation of the doctrine of piercing the corporate veil is that when two business enterprises are owned, conducted and controlled by the same parties, both law and equity will, when necessary to protect the rights of third parties, disregard the legal fiction that these two entities are distinct and treat them as identical or as one and the same. In the present case, it may be true that Lubas is a single proprietorship and not a corporation. However, petitioners' attempt to isolate themselves from and hide behind the supposed separate and distinct personality of Lubas so as to evade their liabilities is precisely what the classical doctrine of piercing the veil of corporate entity seeks to prevent and remedy.[56] | |||||
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2012-01-18 |
PEREZ, J. |
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| Equally settled is the rule that factual findings of labor officials, who are deemed to have acquired expertise in matters within their jurisdiction, are generally accorded not only respect but even finality by the courts when supported by substantial evidence, i.e., the amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.[25] But these findings are not infallible. When there is a showing that they were arrived at arbitrarily or in disregard of the evidence on record, they may be examined by the courts.[26] In this case, there was no showing of any arbitrariness on the part of the lower courts in their findings of facts. Hence, we follow the settled rule. | |||||