G.R. No. 157851 June 29, 2007
ATTY. ANDREA UY and FELIX YUSAY, Petitioners, vs. ARLENE VILLANUEVA and NATIONAL LABOR RELATIONS COMMISSION, Respondents.

FACTS

Countrywide Rural Bank experienced liquidity problems and bank runs in 1998. A group of depositors, holding about 70% of deposit accounts, organized a Committee of Depositors to protect their interests. Petitioners Felix Yusay and Atty. Andrea Uy were elected Chairman and Secretary, respectively, of the Committee’s Interim Board of Directors. With the consent of the incumbent bank Board, the Committee assumed temporary administrative control. The Committee accepted courtesy resignations from some employees, including respondent Arlene Villanueva, who denied having submitted one. The Bangko Sentral ng Pilipinas later placed the bank under receivership.
Villanueva filed an illegal dismissal case. The Labor Arbiter held the bank and petitioners solidarily liable for monetary awards. Petitioners appealed to the NLRC, which initially dismissed the appeal as filed out of time. After a motion for reconsideration, the NLRC reinstated its dismissal. Petitioners then filed a petition for certiorari before the Court of Appeals.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari on technical grounds, and whether petitioners can be held solidarily liable for the employee’s monetary claims.

RULING

The Supreme Court reversed the CA and NLRC resolutions. On procedural grounds, the Court relaxed the rules. The petitioners’ failure to attach certain pleadings to their CA petition was a procedural lapse, but the documents were subsequently submitted with their motion for reconsideration. Technicalities should not hinder substantive justice, especially in labor cases where a party’s livelihood is at stake.
On substantive liability, the Court ruled petitioners cannot be held solidarily liable. The Committee of Depositors was not a distinct juridical entity but an ad hoc group formed to protect depositors’ interests during a crisis. Petitioners, as mere depositors and committee officers, did not become employers. The legal employer remained the bank. Corporate directors or officers are only held solidarily liable for corporate debts if they acted with malice or in bad faith. No such finding was made here. The Labor Arbiter’s decision against petitioners was based solely on Villanueva’s pleadings, as petitioners allegedly were not properly served. Thus, the case was remanded to the Labor Arbiter for proper proceedings to determine the bank’s liability, absolving petitioners from solidary liability.