Londonio v. Bio Research (G.R. No. 191459; January 17, 2011)

CASE DIGEST: BERNADETH LONDONIO AND JOAN CORCORO v. BIO RESEARCH, INC. AND WILSON Y. ANG

FACTS: Petitioners were employees of respondent Bio Research. They were subsequently dismissed from employment. Bio Research claims that due to financial difficulties, it was forced to retrench petitioners in a move towards financial efficiency. Petitioners were made to execute a quitclaim as they were given their separation pay. Petitioners still pursued a complaint with the Labor Arbiter for illegal dismissal. They also claim that the illegal dismissal was done as retaliation for a sexual harassment complaint they filed against one of the company managers. The Labor Arbiter found the dismissal to be illegal as the financial difficulties of Bio Research were unproven, and that no criteria was established in selecting the employees to be let go. The LA ordered for payment of backwages and reinstatement, as well as the subsidiary liability of respondent Ang, for having acted in bad faith. The NLRC, on appeal, affirmed the findings of the LA. Upon appeal to the Court of Appeals, the appellate court affirmed the finding of illegal dismissal, but upheld the quitclaim executed by the petitioners. In addition, the CA found that since there was no proof of bad faith on the part of Respondent Ang, he should not be held subsidiarily liable. Petitioners question these findings in the Supreme Court.ISSUES:  Is the quitclaim is valid?
Is Respondent Ang subsidiarily liable to petitioners?

HELD: A quitclaim does not prevent an illegally dismissed employee from instituting an illegal dismissal case. And since the CA affirmed the findings of illegal dismissal, Bio Research is indeed liable. Petitioners are ordered reinstated, with payment of backwages. If not possible, then a payment of separation pay of one-half month salary for every year served.

The acts of corporate officers, done in behalf of the corporation, are separate from their personal acts. Absent a showing of bad faith, the ruling of the CA is proper. Respondent Ang should not have been held liable for the corporate acts.

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