NLRC affirms labor arbiter's ruling on settlement of dispute in Vibal Group, Inc.
The National Labor Relations Commission (NLRC) has affirmed a settlement agreement that restored Maria Kristine E. Mandigma as chief executive officer (CEO) of Vibal Group, Inc., one of the oldest educational publishing firms in the country,
In an April 6 decision, the NLRC’s fifth division denied the appeal filed by Vibal Group, Inc.
It upheld the Jan. 29, 2026 ruling handed down by Labor Arbiter Raul M. Luna who approved the compromise agreement between Mandigma and Gaspar "Gus" Vibal, who served as the company's chairman and president when the settlement was executed on Sept. 9, 2025.
The agreement, which was forged during a mandatory mediation conference before the labor arbiter, commits the company to reinstate Mandigma to her former position and to pay her P1,000,000 in backwages within 30 days.
In denying Vibal Group’s appeal, the NLRC applied the doctrine of apparent authority -- a legal principle that holds a corporation to the acts of an officer who held himself out as having the power to act, where a third party relied on that representation in good faith.
It pointed out that at the time the agreement was forged, Gus Vibal was the duly installed chairman and president of Vibal Group, was impleaded in the labor case as the responsible corporate officer, appeared personally during the mandatory proceedings, and negotiated and signed the settlement before the labor arbiter in his official capacity.
"Nothing on record indicates that the corporation had previously restricted or publicly repudiated Gaspar's authority as President to handle and settle labor disputes," the decision stated.
The NLRC pointed out: “Thus, to allow respondent corporation to disown the compromise agreement on the ground of lack of board authority would sanction a practice whereby corporations may conveniently evade obligations by invoking undisclosed internal limitations. This is particularly true given the absence of any indication that complainant had knowledge of any internal conflict among the officers or members of the board of respondent corporation. Any alleged discord within the corporation pertains to intra corporate matters which are already beyond the ambit of labor proceedings. Such internal issues cannot be invoked to defeat or impair the rights of an employee, who in the course of official proceedings, dealt in good faith with the corporation's officer.”
The NLRC junked the temporary restraining order sought by the Vibal Group.
It said: “Moreover, granting the temporary restraining order would run counter to the long-standing policy of the law favoring the amicable settlement of labor disputes. Compromise agreements reached before labor tribunals are encouraged as an effective means of expeditiously resolving conflicts and promoting industrial peace.”
It also pointed out: “To restrain the enforcement of such agreement on the basis of internal corporate disagreements would undermine the stability of settlements reached before labor authorities and defeat the very purpose of encouraging parties to voluntarily resolve their disputes.”
The NLRC decision was written by Commissioner Eric Anthony B. Ty with the concurrence of Commissioner Hernan G. Nicdao.
The dispositive portion of the decision:
“Wherefore, the appeal filed by respondent Vibal Group, Inc. is denied. Accordingly, the Decision of Labor Arbiter Raul M. Luna dated 29 January 2026 is hereby affirmed. Respondent Vibal Group, Inc.'s prayer for issuance of a Temporary Restraining Order is denied.”