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    Pamplona Plantation Company Vs Tinghil

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    Jelaine Añides
    Several employees of Pamplona Plantations Company filed complaints for illegal dismissal before the NLRC after they were no longer allowed to work in the plantation. The NLRC dismissed the complaints, claiming the indispensable party of Pamplona Plantation Leisure Corporation was not impleaded. However, the Supreme Court held that dismissal was erroneous, as non-joinder of indispensable parties is not grounds for dismissal. The remedy is to require joining the non-party, which the NLRC did not do by summarily dismissing the complaints. Additionally, the two companies were essentially the same entity.

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    Pamplona Plantation Company Vs Tinghil

    Uploaded by

    Jelaine Añides
    107 views1 page
    Several employees of Pamplona Plantations Company filed complaints for illegal dismissal before the NLRC after they were no longer allowed to work in the plantation. The NLRC dismissed the complaints, claiming the indispensable party of Pamplona Plantation Leisure Corporation was not impleaded. However, the Supreme Court held that dismissal was erroneous, as non-joinder of indispensable parties is not grounds for dismissal. The remedy is to require joining the non-party, which the NLRC did not do by summarily dismissing the complaints. Additionally, the two companies were essentially the same entity.

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    Pamplona Plantation Company vs Tinghil

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    Several employees of Pamplona Plantations Company filed complaints for illegal dismissal before the NLRC after they were no longer allowed to work in the plantation. The NLRC dismissed the complaints, claiming the indispensable party of Pamplona Plantation Leisure Corporation was not impleaded. However, the Supreme Court held that dismissal was erroneous, as non-joinder of indispensable parties is not grounds for dismissal. The remedy is to require joining the non-party, which the NLRC did not do by summarily dismissing the complaints. Additionally, the two companies were essentially the same entity.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    107 views1 page

    Pamplona Plantation Company Vs Tinghil

    Uploaded by

    Jelaine Añides
    Several employees of Pamplona Plantations Company filed complaints for illegal dismissal before the NLRC after they were no longer allowed to work in the plantation. The NLRC dismissed the complaints, claiming the indispensable party of Pamplona Plantation Leisure Corporation was not impleaded. However, the Supreme Court held that dismissal was erroneous, as non-joinder of indispensable parties is not grounds for dismissal. The remedy is to require joining the non-party, which the NLRC did not do by summarily dismissing the complaints. Additionally, the two companies were essentially the same entity.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    Pamplona Plantation Company vs Tinghil

    Facts: Pamplona Plantations Company, Inc. (company for brevity) was organized for the purpose of
    taking over the operations of the coconut and sugar plantation of Hacienda Pamplona where it
    employed several coconut hookers or ‘sakador,’ coconut filers, coconut haulers, coconut scoopers or
    ‘lugiteros,’ and charcoal makers.

    In 1995, "Sometime in 1995, Pamplona Plantation Leisure Corporation was established for the purpose
    of engaging in the business of operating tourist resorts, hotels, and inns, with complementary facilities.

    The issue came about when Rodel Tinghil, Maryglenn Sabihon, and several others were not allowed to
    work in the plantation anymore. This prompted them to file a complaint for illegal dismissal before the
    NLRC. Carlito Tinghil amended his complaint to implead Pamplona Plantation Leisure Corporation while
    all others only impleaded Pamplona Plantations.

    Upon the appeal of this case before the NLRC, it reversed the ruling of the Labor Arbiter contending that
    except Tinghil, all other complainants failed to implead Pamplona Plantation Leisure Corporation, an
    indispensable party and that ‘there exist no employer-employee relation between the parties.

    Issue: WON the case should be dismissed for the non-joinder of the Pamplona Plantation Leisure
    Corporation.? NO

    Held: Granting for the sake of argument that the Pamplona Plantation Leisure Corporation is an
    indispensable party that should be impleaded, NLRC’s outright dismissal of the Complaints was still
    erroneous.

    The non-joinder of indispensable parties is not a ground for the dismissal of an action.34 At any stage of
    a judicial proceeding and/or at such times as are just, parties may be added on the motion of a party or
    on the initiative of the tribunal concerned. If the plaintiff refuses to implead an indispensable party
    despite the order of the court, that court may dismiss the complaint for the plaintiff’s failure to comply
    with the order. The remedy is to implead the non-party claimed to be indispensable.36 In this case, the
    NLRC did not require respondents to implead the Pamplona Plantation Leisure Corporation as
    respondent; instead, the Commission summarily dismissed the Complaints.

    In any event, there is no need to implead the leisure corporation because, insofar as respondents are
    concerned, the leisure corporation and petitioner-company are one and the same entity. Salvador v.
    Court of Appeals37 has held that this Court has "full powers, apart from that power and authority which
    is inherent, to amend the processes, pleadings, proceedings and decisions by substituting as party-
    plaintiff the real party-in-interest."

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