Uy v.

Villanueva

FACTS
Pursuant to the Countrywide Rural Bank of La Carlota (CB) having liquidity and funding problems,
several depositors decided to form a Committee of Depositors.
o The Committee was to protect their collective interests and increase chances of recovering
deposits.
o Yusay: elected Chairman; Uy: elected Secretary (petitioners).
o They also assumed temporary administrative control of CB (approved by the Board).
o They dealt with courtesy resignations tendered by bank employees.
The BSP placed them under receivership, appointed a liquidator, and processed claims for deposits.
Realizing their bid to rehabilitate CB failed, the Committee disbanded,
Eventually, cases for illegal dismissal were filed Amelia Bueno, Amelia Valdex & Lyn Villa, and Arlene
Villanueva (respondent).
o Villanueva: she was a regular employee who received an acceptance of her resignation but
insists that she never sent a resignation letter.
o NLRC: Petitioners are solidarily liable to Villanueva.
o NLRC on appeal: dismissed for being filed out of time, but after a hearing, affirmed liability
o CA: dismissed for technical grounds (ex: no material attachments)
o MR: denied, thus this petition for certiorari
Uy: dismissal on technical grounds = denial of substantial justice
o Further, LAs ruling was based only on Villanuevas pleadings.
Villanueva: petition merely reiterated man arguments and questions of fact that had already been
passed upon; no new gounds.
Meanwhile, in the Bueno case (another illegal dismissal case mentioned in 4th bullet), it was found that
there was no evidence that Uy was elected as interim president and secretary and therefore had no
legal authority to act for CB. this was filed in the present case as a manifestation (like an FYI).

ISSUE + RULING:
Was the dismissal illegal? YES.
Should Petitioners be held liable for the illegal dismissal? NO.
**Re: CivPro issue this case is an exception to Rule 45 grounds in committing GADLEJ because the
merits of the case were not examined first due to mere technicalities.
First, determine whether there was an er-ee relationship using the four-fold test:
1. Whether er has power of selection and engagement of an ee;
2. Whether he has control of the ee with respect to the means and methods by which the work is
to be accomplished; **most important, accdg to the Court**
3. Whether he has the power to dismiss; and
4. Whether the ee was paid wages.
In this case, all elements are attributable to the bank itself, not the petitioners.
o Having been adjudicated by the NLRC decision as final and executory, the banks liability is
setbut not the Petitioners.
They only assumed limited administrative control of the bank as part of the Committee.
There is no showing that they took over the management and control of CB, therefore:
no er-ee relationship between them and Villanueva.
Even assuming that there is a relationship, corporate officers are not personally
responsible for the money claims of discharged employees, unless they acted with
evident malice and bad faith in terminating employment.
Also, piercing of the veil of corporate fiction does not apply because there is no wrong
being justified, no public convenience defeated, etc.
Finally, in Bueno, stare decisis is that Uy is not an officer therefore, she really cannot be held personally
liable.