GR 153193; (December, 2006) (Digest)
G.R. No. 153193 ; December 6, 2006
PAMPLONA PLANTATION COMPANY, petitioner, vs. RAMON ACOSTA, et al., respondents.
FACTS
Sixty-six individuals filed a complaint before the Labor Arbiter against Pamplona Plantation Company for various monetary claims and illegal dismissal. The complainants asserted they were regular employees of the petitioner. The petitioner countered that the complainants were not its employees, alleging some were seasonal workers, contractors, pakyaw workers, or were actually employed by a separate entity, Pamplona Plantation Leisure Corporation. The Labor Arbiter ruled in favor of the complainants, finding them to be regular employees and declaring illegal dismissal for two individuals. The NLRC reversed this, dismissing all complaints upon finding the workers’ affidavits indicated their tasks pertained to a golf course, suggesting employment with the Leisure Corporation. The Court of Appeals then reinstated the Labor Arbiter’s decision with modifications, limiting the award of wage differentials to twenty-two specific respondents and deleting the finding of illegal dismissal for one individual and the award of attorney’s fees.
ISSUE
The primary issues were: (1) whether the twenty-two respondents were employees of Pamplona Plantation Company, and (2) whether the company’s manager, Jose Luis Bondoc, could be held personally liable for the corporate obligations.
RULING
The Supreme Court affirmed the CA’s decision with modification regarding personal liability. On the employment relationship, the Court held petitioner was estopped from denying that the respondents worked for it. Petitioner’s defense before the Labor Arbiter focused on the nature of employment (e.g., seasonal, pakyaw), not the absence of an employer-employee relationship. By presenting company payrolls to support its defense on the nature of work, petitioner effectively admitted employing the respondents. This constituted a “negative pregnant”—a denial that implies an admission of the essential fact alleged. Furthermore, the Court cited a prior case involving the same petitioner, where it was established that Pamplona Plantation Company and Pamplona Plantation Leisure Corporation were one and the same entity, operating as a single enterprise, thus piercing the veil of corporate fiction.
Regarding the manager’s liability, the Court absolved Jose Luis Bondoc. A corporate officer can be held personally liable for employees’ money claims only if he acted with evident malice and bad faith. Merely signing or approving payrolls, as Bondoc did, does not equate to a direct hand in determining wages or demonstrate the required malice. There was no evidence presented that Bondoc acted with such ill will. Therefore, only the corporate entity, Pamplona Plantation Company, was held liable for the awarded wage differentials.