GR 241523; (October, 2020) (Digest)
G.R. No. 241523, October 12, 2020
Daniel F. Tiangco, Petitioner, vs. Sunlife Financial Plans, Inc., Sunlife of Canada (Phils.), Inc., and Rizalina Mantaring, Respondents.
FACTS
Petitioner Daniel F. Tiangco was engaged as an insurance agent by respondent Sun Life of Canada (Philippines), Inc. (SLOCPI) in 1978. In 2000, as part of a business expansion, Sun Life Financial established Sun Life Financial Plans, Inc. (SLFPI) for the pre-need industry, and Tiangco was also engaged as a Sales Consultant under a separate Consultant’s Agreement. Both agreements were terminated on December 10, 2003, following an investigation into a sexual harassment complaint against him. Tiangco later demanded payment of renewal commissions on premiums paid after his termination, primarily from SLFPI’s pre-need plans, totaling P496,148.70. SLFPI denied his claim, citing provisions in the Consultant’s Agreement and asserting full payment of all due commissions.
ISSUE
The core issues are: (1) whether Tiangco is entitled to post-termination renewal commissions, particularly under the theory that SLFPI and SLOCPI should be considered a single entity; and (2) whether he is entitled to a refund of his P50,000.00 cash bond.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. On the first issue, the Court held that Tiangco failed to prove entitlement to post-termination commissions. His reliance on the Agent’s Agreement with SLOCPI, which purportedly granted lifetime commissions after 15 years of service, was irrelevant to his claim against SLFPI. The Consultant’s Agreement with SLFPI, which he undisputedly signed, explicitly stated that commissions after termination were payable only if termination was due to the Sales Consultant’s death, not for termination due to cause, as in his case. The Court also rejected the argument to pierce the corporate veil and treat SLOCPI and SLFPI as a single entity, as Tiangco provided no compelling evidence of fraud, misuse, or clear control justifying disregard of their separate juridical personalities.
On the second issue, the Court upheld the finding that Tiangco failed to secure the necessary clearance from SLFPI for the release of his cash bond. The certification he presented pertained only to his earnings for 2002-2003 and did not constitute the required clearance for bond refund. As the petitioner, he bore the burden of proof, which he did not discharge. The Court emphasized that its review under Rule 45 is limited to questions of law, and Tiangco failed to demonstrate that the case fell under any exception warranting a re-evaluation of the factual findings of the lower courts, which were supported by evidence.