G.R. Nos. 89971-75. October 17, 1990 (Case Brief / Digest)

### Title:
**Chua et al. v. National Labor Relations Commission & Labor Arbiter Dominador M. Cruz**

### Facts:
The legal dispute involved 6,341 former employees of Stanford Microsystems, Inc. (Stanford) who, through their attorneys-in-fact, sought to challenge the jurisdiction of the National Labor Relations Commission (NLRC) concerning the issuing of resolutions related to the payment and distribution of funds to Stanford’s former employees as part of the company’s liquidation process. Stanford had filed for suspension of payments and was declared in a state of suspension by the Securities and Exchange Commission (SEC) in 1986, leading to its eventual liquidation.

Various labor cases were filed by Stanford’s former employees with the Department of Labor and Employment (DOLE) for money claims like illegal lockout, payment of 13th-month pay, and other benefits. These cases were consolidated and were under respondent Labor Arbiter Dominador M. Cruz. Concurrently, a Memorandum of Agreement (MOA) was entered into by Stanford’s secured creditor banks and the majority of its former employees for the liquidation of the company’s assets and distribution of proceeds.

Disputes arose when the Liquidation Committee, formed in accordance with the MOA and appointed by the SEC, began the process of distributing the proceeds, and issues of legal representation and entitlement to attorney’s fees, among other concerns, were raised by certain parties, specifically a group represented by Attorney Vicente T. Ocampo.

### Issues:
1. Whether the NLRC has jurisdiction over the labor cases involving money claims of Stanford’s former employees during the company’s liquidation process.
2. The validity and enforceability of the Memorandum of Agreement (MOA) dated March 13, 1987.
3. The propriety of directing the Stanford Liquidation Committee to deposit deducted attorney’s fees with the NLRC.
4. The representation issue concerning Attorney Vicente T. Ocampo and the employees he claims to represent.

### Court’s Decision:
The Supreme Court of the Philippines granted the petition, declaring the resolutions issued by the NLRC null and void, thereby setting them aside. It ruled that:
1. The NLRC and the Labor Arbiter do not have jurisdiction over the labor cases involving the money claims of Stanford’s former employees in the context of the company’s liquidation process, as these matters fall within the purview of the SEC.
2. The MOA executed among the secured banker creditors and the majority of Stanford’s employees for the liquidation of assets and distribution of proceeds was valid, fair, and reasonable.
3. The NLRC’s directive for the Liquidation Committee to deposit deducted attorney’s fees was premature and lacked jurisdictional basis.
4. Attorney Vicente T. Ocampo’s interference in the implementation of the MOA and the liquidation process was unjustified, given his replacement by the affected employees’ decision represented in the MOA.

### Doctrine:
This case reiterates the doctrine regarding the jurisdiction of the SEC over liquidation proceedings of insolvent corporations, including settling the money claims of former employees, and the enforcement of compromise agreements as voluntary modes of settling labor disputes.

### Class Notes:
– Jurisdiction over corporate liquidation and employee money claims during liquidation: vested in the Securities and Exchange Commission (not the NLRC).
– Validity of Compromise Agreements: Voluntary compromise agreements in labor disputes are legally binding and enforceable.
– Process of Liquidation: The proper process in settling money claims through agreements during a company’s liquidation is recognized and can be enforced against all claimants/parties involved.
– Attorney’s Fees: Claims for attorney’s fees based on contingent contracts must correlate with actual representation and contribution to the secured outcome.

### Historical Background:
The decision highlights the complexities involved in corporate liquidation processes, especially when it intersects with labor claims and disputes. It underscores the legal mechanisms available for resolving such disputes, emphasizing the importance of jurisdiction and adherence to agreed-upon settlements among large groups of employees and creditors within the framework of Philippine corporate and labor laws.


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