Facts:

The case involves Romeo Alba as the petitioner and Conrado G. Espinosa, among others, as respondents. The events leading to the case began when multiple complaints for illegal dismissal and monetary claims were filed against Alba Construction and its owner, Alba, by the respondents. These complaints were lodged with the Arbitration Branch of the National Labor Relations Commission (NLRC) in 2014. The first complaint, NLRC NCR Case No. 06-07959-14, was initiated by Espinosa and several others, while the second complaint, NLRC NCR Case No. 06-07960-14, was filed by another group of workers. The respondents alleged that they were regular employees of Alba, hired for various construction projects across Metro Manila and nearby provinces, and claimed they were denied statutory benefits such as overtime pay, 13th month pay, holiday pay, and service incentive leave (SIL) pay.

The situation escalated when some respondents confronted Alba about their unpaid benefits, leading to the...

Facts:

1. Parties Involved:

   • Petitioner: Romeo Alba, owner of Alba Construction.
   • Respondents: Conrado G. Espinosa and other construction workers (total of 31 respondents).

2. Nature of the Case:

   • Two complaints for illegal dismissal and monetary claims were filed by the respondents against Alba Construction and Romeo Alba.
   • The complaints were consolidated before the Labor Arbiter (LA).

3. Employment Details:

   • Respondents were hired as construction workers for Alba's projects in Metro Manila and nearby provinces.
   • They were paid daily wages ranging from P350.00 to P500.00 but were allegedly deprived of statutory benefits such as overtime pay, 13th month pay, holiday pay, and service incentive leave (SIL) pay.

4. Dismissal:

   • In 2013, some respondents confronted Alba about their unpaid benefits, which led to their dismissal.
   • In 2014, other respondents sought media assistance (Raffy Tulfo's Radyo Singko Program) to address their grievances. After the media intervention, they were dismissed the following day.

5. Alba's Defense:

   • Alba claimed he was a "mamamakyaw" (small-scale contractor) who hired workers for specific projects lasting 1-2 weeks.
   • He argued that the respondents were not regular employees but were paid daily wages ranging from P600.00 to P1,000.00.
   • He presented certifications from clients stating that the clients directly paid the workers' salaries.

6. Respondents' Evidence:

   • Respondents presented gate passes from villages where Alba had projects, indicating Alba was a "contractor."

7. Labor Arbiter's Ruling:

   • The LA dismissed the complaints, ruling that no employer-employee relationship existed. The LA cited that wages were paid by project owners, respondents used their own tools, and received instructions from architects or foremen.

8. NLRC Ruling:

   • The NLRC partially granted the appeal, declaring most respondents as regular employees and ordering their reinstatement, backwages, and payment of statutory benefits.
   • The NLRC dismissed the complaints of Conrado Espinosa and Jaime Ocfemia, Jr., citing sufficient evidence that they were independent contractors.

9. Court of Appeals Ruling:

   • The CA affirmed the NLRC's decision, finding that the four-fold test for employer-employee relationship was satisfied.

Issue:

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Ruling:

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Ratio:

1. Four-Fold Test for Employer-Employee Relationship:

   • The existence of an employer-employee relationship is determined by:
     • Selection and engagement of the employee.
     • Payment of wages.
     • Power of dismissal.
     • Control over the employee's work (control test).

2. Regular Employment vs. Project Employment:

   • Regular employees are those continuously rehired for tasks vital to the employer's business. Project employees are hired for specific projects and their employment ends with the project.

3. Illegal Dismissal:

   • An employer must prove just or valid cause for dismissal and comply with due process. Failure to do so results in illegal dismissal.

4. Monetary Claims:

   • Employees are entitled to statutory benefits such as 13th month pay and SIL pay.
   • Moral and exemplary damages may be awarded if the dismissal is oppressive or in bad faith.
   • Attorney's fees are recoverable if the employee is compelled to litigate due to the employer's unjustified acts.

Conclusion:

The Supreme Court denied Alba's petition and affirmed the CA's decision, holding that the respondents were regular employees illegally dismissed by Alba. Alba was ordered to reinstate the respondents, pay backwages, and provide statutory benefits, moral and exemplary damages, and attorney's fees.