Sie sind auf Seite 1von 2

RICARDO TANTONGCO, petitioner, v.

KAISAHAN NG MGA MANGGAGAWA SA LA


CAMPANA (KKM) and THE HONORABLE COURT OF INDUSTRIAL RELATIONS,
respondents
Ponente: Montemayor, J.
The present case is a petition for Certiorari and prohibition with prayer for the issuance of a writ
of preliminary injunction to prohibit the respondent Court of Industrial Relations from proceeding
with the hearing of the contempt proceedings.
FACTS: La Campana Starch Factory and La Campana Coffee Factory (La Campana for Brevity)
are two separate entities run by a single management under the leadership of Ramon
Tantongco. Kaisahan ng mga Manggagawa sa La Campana (Kaisahan for brevity), on the other
hand, is a labor union with members from the two companies. Sometime in June, 1951,
representatives of Kaisahan approached the management of La Campana to demand higher
wages and more benefits. A deadlock ensued since none of the parties is willing to give
concessions. The dispute was certified to the Court of Industrial Relations (CIR). La Campana
filed a motion to dismiss before the CIR claiming that the CIR has no jurisdiction because only
those from the coffee factory were presenting the demands there were only 14 employees in
said factory. This was done in light of the requirement that at least 31 employees should present
the demands. The motion was denied by the CIR. According to the CIR, the Kaisahan was the
one that presented the demands and not just the workers in the coffee factory. The Supreme
Court affirmed the order of the CIR citing that although the two entities are separate, there is
only one management. The entire membership of the Kaisahan is therefore to be counted and
not simply those employed in the coffee factory.
On June 12, 1956, a partial decision was rendered in the main case No. 584-V, which partial
decision was elevated to us and is still pending appeal. On February 18, 1957, the Court of Industrial
Relations issued an order in incidental Cases No. 584-V(1), V(2), V(5) and V(6), directing the
"management of the respondent company and or the administrator of the Estate of Ramon
Tantongco", to reinstate the dismissed laborers mentioned therein with back wages. This order of
February 18, 1957, as well as the order directing the inclusion of the administrator of the estate of
Ramon Tantongco as additional respondent in the incidental cases, and the order denying the
petition of the administrator to dismiss said incidental cases were appealed to this tribunal though
certiorari. Additional incidental cases were filed by Kaisahan before the CIR including a petition
for the reinstatement of some employees. Ramon Tantongco died some time in 1956. The
administrator of the estate of Ramon Tantongco, herein petitioner Ricardo Tantongco, was
ordered included as respondent in the cases pending before the CIR. The CIR rendered a
decision on the incidental cases and ordered the reinstatement of the dismissed employees.
When the employees reported to work, the management refused them admittance. Kaisahan
then filed a petition to cite the management in contempt before the CIR. Hence this petition.

Contentions
Petitioner: The two companies ceased to exist upon the death of Ramon Tantongco. . The
Supreme Court held in GR No. L-5677 that La Campana and Ramon Tantongco are one based
on the doctrine of piercing the veil of corporate existence. Therefore, the death of Ramon

Tantongco meant the death of La Campana. Since La Campana already ceased to exist, the
CIR no longer has jurisdiction over it. The claims should have been filed with the probate court.
Defendant: La Campana continues to exist despite the death of Ramon Tantongco. The CIR
therefore has jurisdiction when it rendered its decision on the incidental cases. The noncompliance by La Campana therefore amounted to contempt of court.
ISSUE:
1. Did La Campana ceased to exist upon the death of Ramon Tantongco?
2. Is the Doctrine of Piercing the Veil of Corporate Existence applicable to the present
case?
3. Should the contempt of court proceedings in the CIR should proceed?

RULING: The Supreme Court DENIED the Petition for Certiorari and Prohibition. It ruled that La
Camapana continued to exist despite the death of Ramon Tantongco. It further ruled that the
Doctrine of Piercing the Veil of Corporate Existence is not applicable in the present case.
Finally, it allowed the CIR to proceed with the contempt hearing.
On the first and second issues: The death of Ramon Tantongco did not end the existence of La
Campana. The Supreme Court applied the Doctrine of Piercing the Veil of Corporate Existence
in GR no. L-5677 to avoid the use of technicality to defeat the jurisdiction of the CIR. In the said
case, the Court determined that although La Campana are two separate companies, they are
being managed by only one management. Furthermore, the workers of both factories were
interchangeably assigned. In the present case, however, the Court ruled that despite the
obvious fact that La Campana was run by the same people, they still are two different
companies with separate personalities from Ramon Tantongco. La Campana was owned not
only by Ramon but others as well including Ricardo Tantongco. Lastly, the Court ruled that
petitioner is under estoppel and cannot claim that La Campana and Ramon are one and the
same since he has represented La Campana as separate entities in numerous dealings.
On the third issue: Ricardo Tantongco should still face the contempt proceedings because under
Section 6 of Commonwealth Act No. 143, In case the employer (or landlord) committing any
such violation or contempt is an association or corporation, the manager or the person who has
the charge of the management of the business of the association or corporation and the officers
of directors thereof who have ordered or authorized the violation of contempt shall be liable. . . .
Since Tantongco is the General Manager of La Campana, he is still obliged to appear at the
contempt proceedings.