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GR NO 159119, March 14, 2006 Uy vs. Bueno Facts

This case involves a dispute between Andrea Uy and Amalia Bueno regarding Bueno's termination as branch manager of Countrywide Rural Bank. [1] Countrywide Rural Bank experienced liquidity problems in 1998. A committee of depositors, including Uy, was organized to address this. [2] In 1999, at a meeting of Countrywide depositors, Uy confirmed Bueno's statement that Bueno was terminated as branch manager, but did not provide details. [3] The court ultimately found that the committee of depositors led by Uy was not legally recognized by banking authorities, so Uy's termination of Bueno could not be considered an act as a bank officer. Without an employer-employee relationship

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144 views

GR NO 159119, March 14, 2006 Uy vs. Bueno Facts

This case involves a dispute between Andrea Uy and Amalia Bueno regarding Bueno's termination as branch manager of Countrywide Rural Bank. [1] Countrywide Rural Bank experienced liquidity problems in 1998. A committee of depositors, including Uy, was organized to address this. [2] In 1999, at a meeting of Countrywide depositors, Uy confirmed Bueno's statement that Bueno was terminated as branch manager, but did not provide details. [3] The court ultimately found that the committee of depositors led by Uy was not legally recognized by banking authorities, so Uy's termination of Bueno could not be considered an act as a bank officer. Without an employer-employee relationship

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Dany
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GR NO 159119, March 14, 2006

UY VS. BUENO

FACTS:

Countrywide Rural Bank, is a private banking corporation duly licensed and organized to engage in rural banking
operations that offers a wide-range of deposit, financial and lending services through its network of branches
nationwide. In April 1998, Countrywide Rural Bank experienced liquidity problems. A group of its depositors,
alarmed at the imminent prospect of not being able to recover their deposits and other investments, organized
themselves into a committee of depositors. The committee elected petitioner Felix Yusay as Chairman, petitioner
Andrea Uy as Secretary, Manu Gidwani as Vice-Chairman and Pompeyo Querubin as Treasurer.

On January 18, 1999, the depositors of Countrywide Rural Bank - not the committee of depositors led by
petitioner Yusay - met at the Marbel Branch. In the course of the meeting, respondent Amalia A. Bueno stood up
and announced that her services as Branch Manager of Marbel Branch were terminated by petitioner Uy.
Petitioner Uy, who was in the meeting, confirmed respondent Buenos declaration. She did not elaborate on the
basis of the termination explaining that it involved internal problems that could not be discussed with the
depositors.

HELD:

The findings of the Labor Arbiter, the NLRC and the CA as to the liability of petitioner Uy are conflicting, thus, the
application of the exception to the rule that only legal issues may be raised in a petition for review on certiorari
under Rule 45 of the Rules of Court.

Whether petitioner Uy should be held solidarily liable with Countrywide Rural Bank in the illegal dismissal of
respondent Bueno, depends on the jurisdiction of the Labor Arbiter over the case at bar

The records show that petitioner Uy was a mere depositor of the bank who was elected Interim President and
Corporate Secretary by a committee of depositors to protect their interests given the bad state of Countrywide
Rural Banks affairs. In his findings, the Labor Arbiter mentioned the meeting of the depositors on January 18, 1999
but he failed to account for the exact personality of petitioner Uy whose statement relative to her role in the
affairs of Countrywide Rural Bank was related in the minutes of the same meeting. It was only through the NLRC
that petitioner Uys role was established, i.e., that she was one of the depositors of Countrywide Rural Bank who
formed themselves into a group or association indicating their intention to help rehabilitate Countrywide Rural
Bank.

Clearly, even respondent Bueno was uncertain as to the exact role of the Interim Board that elected petitioner Uy
as Interim President and Corporate Secretary. She herself questioned the personality of the Interim Board in the
management of Countrywide Rural Bank even while she alleged that petitioner Uy as its Interim President and
Corporate Secretary caused her dismissal. More significantly, there is no evidence that the committee of
depositors that elected petitioner Uy as Interim President and Corporate Secretary was recognized by the Bangko
Sentral ng Pilipinas, and hence had the legal authority to act for the bank.

Lacking this evidence, the act of petitioner Uy in dismissing respondent cannot be deemed an act as an officer of
the bank. Consequently, it cannot be held that there existed an employer-employee relationship between
petitioner Uy and respondent Bueno when the former allegedly dismissed the latter. This requirement of
employer-employer relationship is jurisdictional for the provisions of the Labor Code, specifically Book VI thereof,
on Post-Employment, to apply. Since the employer-employee relationship between petitioner Uy and respondent
Bueno was not established, the labor arbiter never acquired jurisdiction over petitioner Uy. Consequently, whether
petitioner Uy was properly served with summons is immaterial. Likewise, that she terminated the services of
respondent Bueno in bad faith and with malice is of no moment. Her liability, if any, should be determined in
another forum. –XXX-

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