G.R. No. 191459 ; January 17, 2011
BERNADETH LONDONIO AND JOAN CORCORO, Petitioners, vs. BIO RESEARCH, INC. AND WILSON Y. ANG, Respondents.

FACTS

Petitioners Bernadeth E. Londonio and Joan T. Corcoro were hired by respondent Bio Research, Inc. as graphic/visual artists in 2004. On April 30, 2005, Bio Research issued a memorandum informing employees, including petitioners, of its plan to reduce its workforce to prevent losses, and subsequently filed an Establishment Termination Report with the DOLE on May 9, 2005, citing retrenchment due to redundancy and to prevent losses. Bernadeth was retrenched on May 26, 2005, and Joan on May 18, 2005. Joan accepted her retrenchment pay of ₱9,990.14 and executed a Quitclaim and Waiver releasing Bio Research from all claims. Bernadeth refused to accept hers.
Petitioners filed a complaint for illegal dismissal, moral and exemplary damages, and attorney’s fees against Bio Research and its President/CEO Wilson Y. Ang. They alleged their dismissal was retaliatory and in bad faith, following Bernadeth’s filing of a sexual harassment complaint against a company manager, Jose Ang, Jr., on February 19, 2005. They claimed management pressured Joan to convince Bernadeth to drop the complaint. An administrative investigation was conducted, but the manager resigned on April 15, 2005, before its resolution. Joan also noted she was recommended for regularization on April 12, 2005, shortly before the retrenchment memorandum.
Bio Research maintained the dismissal was due to financial reverses and argued Joan was estopped from challenging her dismissal due to the quitclaim. The Labor Arbiter ruled in favor of petitioners, finding illegal dismissal due to lack of proof of financial losses, failure to use fair criteria for retrenchment, and non-compliance with the one-month notice requirement under Article 283 of the Labor Code. The LA also held Joan’s quitclaim was invalid as it was executed under force, as her salary was conditioned on signing it. The NLRC affirmed the LA’s decision. The Court of Appeals partially granted Bio Research’s petition, sustaining the illegal dismissal finding but ruling that Joan could no longer question her dismissal due to the quitclaim, absolving Wilson Y. Ang from solidary liability, and deleting the awards of moral and exemplary damages.

ISSUE

1. Whether petitioner Joan Corcoro is barred from questioning the validity of her dismissal due to her execution of a quitclaim and waiver.
2. Whether petitioners are entitled to moral and exemplary damages.
3. Whether respondent Wilson Y. Ang is solidarily liable with Bio Research, Inc. for the money claims.

RULING

1. On the quitclaim: The Supreme Court, citing the appellate court’s decision, held that petitioner Joan Corcoro is barred from questioning the legality of her dismissal due to her execution of the quitclaim and waiver. The Court found no merit in petitioners’ contention otherwise, as the appellate court’s affirmance of the NLRC’s factual findings on illegal dismissal was binding, but it specifically modified the ruling regarding Joan based on the quitclaim.
2. On moral and exemplary damages: The Court upheld the appellate court’s deletion of the awards of moral and exemplary damages. The appellate court had found no basis for such awards, and the Supreme Court found no reason to reverse this, as the factual findings of the lower courts were accorded finality.
3. On solidary liability of Wilson Y. Ang: The Court sustained the appellate court’s ruling absolving Wilson Y. Ang from solidary liability. The appellate court held that a corporation has a separate legal personality, and corporate officers are only solidarily liable in exceptional circumstances, such as when malice or bad faith is shown. Since petitioners failed to demonstrate that Ang acted with malice or bad faith in their dismissal, he could not be held solidarily liable.
The Supreme Court denied the petition, affirming the Court of Appeals’ decision with modifications, which included dismissing Joan Corcoro’s complaint due to the quitclaim, deleting the damages awards, and absolving Wilson Y. Ang from solidary liability. The Court emphasized that the factual findings of the Labor Arbiter, NLRC, and Court of Appeals on the illegal dismissal (except as to Joan due to the quitclaim) were binding, as they were supported by substantial evidence and no grave abuse of discretion was shown.