G.R. No. 117890 – 344 Phil. 723 – 279 SCRA 312 – Mercantile Law – Corporation Law – Suit Under a Corporate Name – A corporation may be liable in labor cases despite not receiving summons
In 1988, a labor case for illegal dismissal was filed against Jose Edmundo Pison and Hacienda Lanutan. The labor arbiter issued a favorable decision for the dismissed workers. Pison appealed and the National Labor Relations Commission (NLRC) affirmed the labor arbiter. However, in the NLRC ruling, it ordered Pison-Arceo Agricultural and Development Corporation (PADC) as solidarily liable together with Pison and the Hacienda, PADC being the owner of the Hacienda and in which Pison is a majority stockholder. PADC assails the order of the NLRC on due process grounds as it averred that it was not issued summons hence it was not able to defend itself in court and therefore the judgment against it is void.
ISSUE: Whether or not the contention of PADC is correct.
HELD: No. The Supreme Court emphasized that in labor cases and other administrative cases, the Rule of Civil Procedure are not strictly applied especially so in the interest of laborers. So long as there is a substantial compliance, a party can be placed under the jurisdiction of the labor court. In the case at bar, there is substantial compliance when summons was served to Jose Edmundo Pison who was also the administrator of the Hacienda. PADC is therefore adequately represented by Pison in the proceedings in the labor tribunal. If at all, the non-inclusion of the corporate name of PADC in the case before the executive labor arbiter was a mere procedural error which did not at all affect the jurisdiction of the labor tribunals.
