GR 117890; (September, 1997) (Digest)
G.R. No. 117890 September 18, 1997
PISON-ARCEO AGRICULTURAL AND DEVELOPMENT CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and NATIONAL FEDERATION OF SUGAR WORKERS-FOOD AND GENERAL TRADE (NFSW-FGT)/JESUS PASCO, et al., respondents.
FACTS
Private respondents, sugar farm workers, filed a complaint for illegal dismissal against “Hacienda Lanutan/Jose Edmundo Pison.” Jose Edmundo Pison claimed he was merely the administrator of Hacienda Lanutan, which was owned by petitioner Pison-Arceo Agricultural and Development Corporation. The Executive Labor Arbiter rendered a decision in favor of the workers, holding “Jose Edmundo Pison/Hda. Lanutan” liable for backwages and separation pay. On appeal, the National Labor Relations Commission (NLRC) affirmed the decision but modified it by ordering “Jose Edmundo Pison and the respondent Pison-Arceo Agricultural and Development Corporation to pay jointly and severally.” The corporation was not formally impleaded in the original complaint.
ISSUE
Whether the NLRC acted without jurisdiction or with grave abuse of discretion in motu proprio including the petitioner corporation as a party respondent and holding it jointly and severally liable with its administrator.
RULING
The Supreme Court ruled that the NLRC did not commit grave abuse of discretion. The legal logic is anchored on the principle that a corporation has a separate juridical personality, but this can be disregarded to prevent injustice, especially in labor cases where a speedy and equitable resolution is paramount. The Court found that the corporation and its trade name “Hacienda Lanutan” were one and the same entity. The complaint was filed against the hacienda, which was merely the unregistered trade name of the corporation. Therefore, the corporation was, in substance, a party to the case from the beginning. The NLRC’s act of formally naming the corporation did not violate due process, as it merely corrected a misnomer and identified the real employer. The Court emphasized that technical rules of procedure are not strictly applied in labor proceedings to ensure that substantial justice is served. The corporation, as the actual owner, cannot evade liability by hiding behind its administrator when the latter was clearly acting in a representative capacity. The inclusion was a formal recognition of an existing party, not the addition of a new one, and thus within the NLRC’s adjudicatory powers.