G.R. No. 184520, 13 March 2013
The petitioner was initially hired by RBSJI as Personnel and Marketing Manager in 1991. In June 1996, the petitioner was offered the position of Vice-President for RBSJI’s newly created department, Allied Business Ventures. He accepted the offer and concomitantly relinquished his post.
On September 24, 1996, the petitioner was temporarily assigned as the manager of RBSJI’s N. Domingo branch in view of the resignation of Jacinto Figueroa. On September 27, 1996, Jacinto requested the petitioner to sign a standard employment clearance pertaining to his accountabilities with RBSJI. When the petitioner declined his request, Jacinto threw a fit and shouted foul invectives. To pacify him, the petitioner bargained to issue a clearance but only for Jacinto’s paid cash advances and salary loan.
The unauthorized issuance of a clearance to Jacinto whose accountabilities were yet to be audited led to the petitioner’s dismissal.
The petitioner insists that the alleged loss of trust and confidence in him is a mere subterfuge to cover the respondents’ ploy to oust him out of RBSJI. On the other hand, the respondents invoke the ratiocinations of the CA that they were justified in losing the trust and confidence reposed on the petitioner since he failed to exercise the degree of care expected of his managerial position. The LA ruled in the petitioner’s favor. The respondents disagreed with the LA and appealed to the NLRC, which reversed the LA’s ruling. The petitioner sought reconsideration and the NLRC reversed its decision. CA reversed the NLRC decision favoring respondents.
Among other things, solidary liability of individual respondents as corporate officers was emphasized for petitioner’s illegal dismissal.
Whether respondents should be solidarily liable with the corporation for illegally dismissing the petitioner without justifiable cause evidencing bad faith.
NO. The solidary liability of individual respondents as corporate officers must be recalled. The individual respondents cannot be made solidarily liable with RBSJI for the illegal dismissal. Time and again, the Court has held that a corporation has its own legal personality separate and distinct from those of its stockholders, directors or officers.
Hence, absent any evidence that they have exceeded their authority, corporate officers are not personally liable for their official acts. Corporate directors and officers may be held solidarily liable with the corporation for the termination of employment only if done with malice or in bad faith. As discussed above, the acts imputed to the respondents do not support a finding of bad faith.
In addition, the lack of a valid cause for the dismissal of an employee does not ipso facto mean that the corporate officers acted with malice or bad faith. There must be an independent proof of malice or bad faith, which is absent in the case at bar.
*Case digest by Earl M. Acoymo, Refresher, Andres Bonifacio Law School, SY 2019-2020