GR 90856; (February, 1996) (Digest)
G.R. No. 90856; February 1, 1996
Arturo De Guzman, petitioner, vs. National Labor Relations Commission, (2nd Division), Labor Arbiter Ma. Lourdes A. Sales, Avelino D. Valles-Terol, Alejandro Q. Frias, Linda Dela Cruz, Corazon M. Dela Fuente, Lilia F. Floro, and Mario F. Jayme, respondents.
FACTS
Petitioner Arturo De Guzman was the general manager of Affiliated Machineries Agency, Ltd. (AMAL). Respondent employees filed a complaint for illegal dismissal and non-payment of statutory benefits against AMAL after it ceased operations in 1986. The employees impleaded De Guzman, alleging he sold part of AMAL’s assets, applied the proceeds and remaining assets to satisfy his personal claims against the company, and formed a new corporation engaging in the same business with AMAL’s former clients.
The Labor Arbiter and the National Labor Relations Commission (NLRC) held De Guzman jointly and severally liable with AMAL for the employees’ monetary claims. On certiorari, the Supreme Court modified the decision, absolving De Guzman from solidary liability for the claims, as the decision to cease operations was AMAL’s alone. However, the Court found he acted in bad faith by appropriating company assets to the prejudice of the employees’ pending claims. It thus ordered him to pay moral and exemplary damages and to return the appropriated assets or their value.
ISSUE
Whether the Supreme Court correctly assumed jurisdiction to award damages and order the return of assets against De Guzman, despite the absence of an employer-employee relationship between him and the private respondents, in a complaint for illegal dismissal.
RULING
Yes. The Supreme Court denied De Guzman’s motion for reconsideration, affirming the award. The Court clarified that for a claim to fall within the jurisdiction of labor arbiters, it is not required to arise directly from an employer-employee relationship. It suffices that there is a reasonable causal connection between the claim and the employment relations.
Here, De Guzman’s acts of bad faith were an offshoot of the termination of the employees’ relations with AMAL. The company’s closure impelled him to appropriate its assets, thereby rendering the satisfaction of the employees’ legitimate claims impossible. His acts were facilitated by his position as general manager. Thus, the claim for damages, while not springing directly from the dismissal, was clearly intertwined with it. His argument of legal compensation was untenable as it disregarded the rules on concurrence and preference of credits, to the detriment of other creditors like the employees. The labor tribunal had jurisdiction to adjudicate these ancillary claims integral to the labor dispute’s resolution.