Case Digest (G.R. No. 161083)
Facts:
A. Nate Casket Maker and/or Armando and Anely Nate v. Elias V. Arango, et al., G.R. No. 192282, October 05, 2016, Supreme Court Third Division, Peralta, J., writing for the Court.Petitioners A. Nate Casket Maker (through owners/proprietors Armando and Anely Nate) employed the various respondents as carpenters, mascilladors and painters from 1998 until March 2007 in their casket-making business. Petitioners maintained that the workers were pakyaw (piece-rate) employees and presented job orders to show intermittency of work; respondents contended they actually worked regular hours (Monday–Saturday, long daytime/evening hours) without overtime or other monetary benefits and filed a complaint for illegal dismissal and unpaid wages and benefits.
On February 3, 2007 petitioners presented respondents a written five-month employment contract (renewable, piece-rate, denying sick/vacation/13th-month pay and other benefits). Respondents filed a Complaint with the NLRC on February 8, 2007 (initially for money claims and, after events on March 15, amended to add illegal dismissal). Respondents allege that when they refused to sign on March 15, 2007 they were told to go home and not report back.
The Labor Arbiter (LA) Eduardo J. Carpio dismissed respondents’ complaint on August 15, 2007, finding no proof of dismissal and holding that pakyaw workers, though deemed regular, were not entitled to the monetary claims asserted. The National Labor Relations Commission (NLRC), Sixth Division, affirmed the LA’s decision on July 29, 2008 and denied reconsideration. Respondents petitioned the Court of Appeals (CA) for certiorari; the CA reversed and set aside the NLRC on January 6, 2010, declaring respondents illegally dismissed and ordering backwages, separation pay and other monetary benefits, and directing the Labor Arbiter to determine amounts; the CA denied petitioners’ motion for reconsideration on May 13, 2010.
Petitioners then filed a petition for review on certiorari under Rule 45 of the Rules of Court seeking reversal of the CA decision, principally arguing that the CA gravely abused its discretion and that there were errors in factual findings; respondents answered that the Rule 45 petition raises primari...(Pro-only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion in reversing the NLRC and declaring that respondents were illegally dismissed (i.e., was the CA correct in finding grave abuse by the NLRC)?
- Was respondents’ employment terminated, such that they were illegally dismissed?
- Are respondents (pakyaw/piece-rate workers who are deemed regular employees) entitled to overtime pay, holiday pay, service ince...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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