GR 157802; (October, 2010) (Digest)
G.R. No. 157802; October 13, 2010
MATLING INDUSTRIAL AND COMMERCIAL CORPORATION, ET AL., Petitioners, vs. RICARDO R. COROS, Respondent.
FACTS
Respondent Ricardo R. Coros was dismissed from his position as Vice President for Finance and Administration of petitioner Matling Industrial and Commercial Corporation. He filed a complaint for illegal dismissal before the Labor Arbiter. Petitioners moved to dismiss the complaint, asserting that the Labor Arbiter lacked jurisdiction. They argued that Coros was a corporate officer, being both a Vice President and a member of the Board of Directors, and thus his removal constituted an intra-corporate dispute falling under the jurisdiction of the Securities and Exchange Commission (SEC), and later, the Regional Trial Court.
Coros opposed the motion, contending he was not a bona fide corporate officer. He claimed his directorship was doubtful as he was never formally elected, did not own any stock, and the stock certificate issued to him had been taken back by the company. He emphasized that his dismissal notice pertained solely to his managerial position as Vice President, not to his purported role as a Director.
ISSUE
Whether the Labor Arbiter has jurisdiction over the complaint for illegal dismissal, which hinges on the determination of whether respondent Ricardo R. Coros was a corporate officer or a regular employee.
RULING
The Supreme Court ruled that the Labor Arbiter has jurisdiction. The legal logic centers on the distinction between a corporate officer and an ordinary corporate employee. Jurisdiction over dismissal cases depends on this classification: disputes involving corporate officers are intra-corporate and fall under the jurisdiction of the regular courts, while those involving regular employees fall under the Labor Arbiter’s jurisdiction.
A corporate officer is one who is appointed or elected in accordance with the corporation’s by-laws or by a specific act of the board of directors. The Court examined Matling’s by-laws, which explicitly listed only the President, Executive Vice President, Secretary, and Treasurer as the corporate officers. The position of Vice President for Finance and Administration was not included. The Court held that a corporate title, by itself, does not confer the legal status of a corporate officer. Since Coros’s position was not created by the corporation’s by-laws nor by a board resolution, and his appointment was not shown to be by the board or stockholders, he was deemed a regular employee. His alleged directorship was immaterial to his dismissal from his managerial post. Consequently, his complaint for illegal dismissal was correctly cognizable by the Labor Arbiter and the National Labor Relations Commission. The petitions were denied.