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T & H SHOPFITTERS CORPORATION/GIN QUEEN CORPORATION v. T & H SHOPFITTERS CORPORATION/GIN QUEEN WORKERS UNION

FACTS:

In the case, the NLRC determined that the petitioners were guilty of conducting an illegal lockout. According to the NLRC's findings, the transfer of 17 workers to the Subic Bay Freeport Zone (SBFZ) and the subsequent repeated orders for them to go on forced leave constituted an illegal lockout. The NLRC also noted that the transfer of the working site by Gin Queen Corporation was deemed unfair labor practice by the petitioners. The NLRC opined that the expiration of the lease contract and the management's decision to relocate for cost-cutting purposes were not valid grounds for the transfer. As a result of its findings, the NLRC instructed the petitioners to pay each of the complainants moral and exemplary damages, as well as attorney's fees.

ISSUES:

  1. Whether or not T & H Shopfitters Corporation and Gin Queen Corporation are one and the same corporation.

  2. Whether or not Gin Queen Corporation is liable for unfair labor practice.

  3. Whether or not the award of moral and exemplary damages in favor of the respondents is proper.

  4. Whether or not the award of ten percent attorney's fees in favor of the respondent is proper.

  5. Whether the acts of petitioners constitute unfair labor practices (ULP)

  6. Whether the award of attorney's fees is justified

  7. Whether or not the Writ of Habeas Data applies to a private individual.

RULING:

  1. The Supreme Court held that the argument of petitioners that T & H Shopfitters Corporation and Gin Queen Corporation are separate and distinct corporations is without merit. The Court ruled that based on the evidence presented, it is clear that T & H Corporation and Gin Queen Corporation are engaged in the same line of business. The Court also noted that the respondents did not controvert the allegations that Myra D. Lumibao, the supposed lessor of respondent corporations, is the wife of respondent Stennis Huang, and that Gin Queen Corporation has been renamed 'MDL', but still carries on the same business in the same premises using the same machines and facilities. These circumstances, together with the supposed assignment of respondent Stennis Huang's interest in Gin Queen Corporation to a third party, justify the piercing of the veil of corporate fiction. Therefore, petitioners T & H Shopfitters Corporation and Gin Queen Corporation are considered as one and the same entity.

  2. Regarding the issue of unfair labor practice, the Court affirmed the finding of the NLRC that petitioners committed unfair labor practice acts, such as interfering with the exercise of the employees' right to self-organization and discriminating in regard to conditions of employment to discourage union membership.

  3. The Court also upheld the award of moral and exemplary damages in favor of the respondents, as well as the grant of attorney's fees. It stated that in cases of unfair labor practice, moral and exemplary damages may be awarded as a deterrent to the commission of similar acts in the future. The Court also recognized the entitlement of the prevailing party to attorney's fees.

  4. The Court found that the acts of petitioners, such as sponsoring a field trip to Zambales for its employees, actively campaigning against the union during the field trip, escorting employees to the polling center, continuous hiring of subcontractors, assigning union members to unfavorable work, and enforcing rotational work for union members, constituted unfair labor practices. These acts interfered with the free exercise of the employees' right to self-organization. The Court emphasized that the test for determining interference with the right to self-organization is whether the employer's conduct reasonably tends to interfere with the exercise of such rights, and it is not necessary to prove direct intimidation or coercion of employees.

  5. The award of attorney's fees was not justified because there was no claim or proof that petitioners unlawfully withheld the wages of the respondents. The applicable law for the grant of attorney's fees in labor cases is limited to cases of unlawful withholding of wages.

  6. The Court affirmed the decision of the Court of Appeals, with the exception of the award of attorney's fees which was deleted. The Court held that the Writ of Habeas Data is applicable to private individuals, as it is a remedy available to any person whose right to privacy in life, liberty, or security is violated or threatened by an unlawful act or omission of a public official or employee.

PRINCIPLES:

  • The veil of corporate fiction may be pierced when there is fraud or when corporations are used to evade compliance with the law.

  • Unfair labor practices of employers, such as interfering with the exercise of employees' right to self-organization and discriminating in regard to conditions of employment to discourage union membership, are prohibited.

  • Moral and exemplary damages may be awarded in cases of unfair labor practice as a deterrent to similar acts in the future.

  • The prevailing party in a labor case is entitled to attorney's fees.

  • Unfair labor practices (ULP) violate the constitutional right of workers and employees to self-organization and disrupt industrial peace. ULP refers to the commission of acts that transgress the workers' right to organize.

  • The test for interference with the right to self-organization is whether the employer's conduct reasonably tends to interfere with the exercise of such rights. Direct evidence of intimidation or coercion is not necessary if there is a reasonable inference that anti-union conduct of the employer adversely affects self-organization and collective bargaining.

  • In labor cases, the quantum of proof necessary is substantial evidence, or that amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion.

-Note: The partial digest provided would require more specific details from the facts to provide a complete digest. The provided section only focuses on the issues, ruling, and principles derived from the ruling.)

  • The Writ of Habeas Data applies not only to public officials or employees but also to private individuals whose right to privacy is violated or threatened.

  • The Writ of Habeas Data is a remedy available to any person whose right to privacy in life, liberty, or security is violated or threatened by an unlawful act or omission.