G.R. No. L-20502 February 26, 1965
EMILIO CANO ENTERPRISES, INC., petitioner, vs. COURT OF INDUSTRIAL RELATIONS, ET AL., respondents.

FACTS

A complaint for unfair labor practice was filed before the Court of Industrial Relations against Emilio, Ariston, and Rodolfo Cano as officials of Emilio Cano Enterprises, Inc. After trial, the court found Emilio Cano (president) and Rodolfo Cano (manager) guilty and ordered them, jointly and severally, to reinstate Honorata Cruz to her former position with payment of backwages. Emilio Cano died during the proceedings. The court en banc affirmed the decision. An order of execution was issued directing the reinstatement and the deposit of backwages, threatening levy on respondents’ properties. This order was directed against the properties of Emilio Cano Enterprises, Inc. The corporation filed a motion to quash the writ, arguing it was a separate juridical entity not named in the judgment. The motion was denied, prompting this certiorari petition.

ISSUE

Can the judgment rendered against Emilio and Rodolfo Cano in their official capacity as president and manager of Emilio Cano Enterprises, Inc. be enforced against the property of the corporation, which was not formally named as a party to the case?

RULING

Yes. The Supreme Court dismissed the petition. While a corporation has a separate legal personality, the doctrine of piercing the corporate veil applies. Emilio Cano Enterprises, Inc. is a closed family corporation where incorporators and directors belong to one family. The legal fiction of separate identity cannot be invoked to use it as a shield to subvert justice. Emilio and Rodolfo Cano were sued in their official capacities, and the court’s order for reinstatement and backwages was effectively against the corporation. Remanding for mere technical substitution of parties would cause undue delay, contrary to the speedy adjudication principle in labor cases. Thus, the order of execution against the corporate property is valid.