Tantongco vs. Kaisahan (106 Phil 199)
Tantongco vs. Kaisahan (106 Phil 199)
Contentions
Petitioner: The two companies ceased to exist upon the death of Ramon Tantongco. . The
Supreme Court held in GR No. L-5677 that La Campana and Ramon Tantongco are one based
on the doctrine of piercing the veil of corporate existence. Therefore, the death of Ramon
Tantongco meant the death of La Campana. Since La Campana already ceased to exist, the
CIR no longer has jurisdiction over it. The claims should have been filed with the probate court.
Defendant: La Campana continues to exist despite the death of Ramon Tantongco. The CIR
therefore has jurisdiction when it rendered its decision on the incidental cases. The noncompliance by La Campana therefore amounted to contempt of court.
ISSUE:
1. Did La Campana ceased to exist upon the death of Ramon Tantongco?
2. Is the Doctrine of Piercing the Veil of Corporate Existence applicable to the present
case?
3. Should the contempt of court proceedings in the CIR should proceed?
RULING: The Supreme Court DENIED the Petition for Certiorari and Prohibition. It ruled that La
Camapana continued to exist despite the death of Ramon Tantongco. It further ruled that the
Doctrine of Piercing the Veil of Corporate Existence is not applicable in the present case.
Finally, it allowed the CIR to proceed with the contempt hearing.
On the first and second issues: The death of Ramon Tantongco did not end the existence of La
Campana. The Supreme Court applied the Doctrine of Piercing the Veil of Corporate Existence
in GR no. L-5677 to avoid the use of technicality to defeat the jurisdiction of the CIR. In the said
case, the Court determined that although La Campana are two separate companies, they are
being managed by only one management. Furthermore, the workers of both factories were
interchangeably assigned. In the present case, however, the Court ruled that despite the
obvious fact that La Campana was run by the same people, they still are two different
companies with separate personalities from Ramon Tantongco. La Campana was owned not
only by Ramon but others as well including Ricardo Tantongco. Lastly, the Court ruled that
petitioner is under estoppel and cannot claim that La Campana and Ramon are one and the
same since he has represented La Campana as separate entities in numerous dealings.
On the third issue: Ricardo Tantongco should still face the contempt proceedings because under
Section 6 of Commonwealth Act No. 143, In case the employer (or landlord) committing any
such violation or contempt is an association or corporation, the manager or the person who has
the charge of the management of the business of the association or corporation and the officers
of directors thereof who have ordered or authorized the violation of contempt shall be liable. . . .
Since Tantongco is the General Manager of La Campana, he is still obliged to appear at the
contempt proceedings.