Title
Apex Mining Co., Inc. vs. National Labor Relations Commission
Case
G.R. No. 94951
Decision Date
Apr 22, 1991
Sinclitica Candido, a laundry worker at Apex Mining's staff house, was injured on duty and later dismissed. The Supreme Court ruled her a regular employee, not a domestic helper, affirming illegal dismissal and entitlement to separation pay.
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Case Digest (G.R. No. 94951)

Facts:

    Employment and Payment Details

    • Private respondent Sinclitica Candido was hired by Apex Mining Company, Inc. on May 18, 1973, to render laundry services at the company’s staff house in Masara, Maco, Davao del Norte.
    • Initially, her compensation was based on a piece rate system.
    • On January 17, 1982, her payment method changed to a monthly salary, starting at P250.00 per month, which was subsequently raised to P575.00 per month.

    The Workplace Accident and Its Aftermath

    • On December 18, 1987, while performing her laundry duties—specifically hanging laundry—Sinclitica accidentally slipped and struck her back on a stone.
    • She immediately reported the incident to her immediate supervisor, Mila de la Rosa, and to the personnel officer, Florendo D. Asirit.
    • Following the accident, she was unable to continue working and was granted leave for medication.

    Subsequent Developments and Employer’s Actions

    • In an effort to persuade her to quit, her supervisor de la Rosa first offered her a sum of P2,000.00, which was later increased to P5,000.00.
    • Despite the offer, Sinclitica preferred to return to work.
    • Ultimately, the petitioner did not permit her to resume her duties and dismissed her on February 4, 1988.

    Filing of the Case and Procedural History

    • On March 11, 1988, following her dismissal, Sinclitica filed a request for assistance with the Department of Labor and Employment.
    • After the parties submitted their position papers, the labor arbiter rendered a decision on August 24, 1988.
    • The decision ordered Apex Mining Company, Inc. to pay various monetary components which included:
    • Salary Differential amounting to P16,289.20
    • Emergency Living Allowance of P12,430.00
    • 13th Month Pay Differential of P1,322.32
    • Separation Pay calculated at one-month for every year of service from 1973 to 1988, totaling P55,161.42.
    • Dissatisfied with this decision, Apex Mining Company, Inc. appealed to the National Labor Relations Commission (NLRC).
    • The Fifth Division of the NLRC affirmed the labor arbiter's decision on July 20, 1989, and a subsequent motion for reconsideration in June 1990 was denied.

    Central Issue Raised in the Petition

    • The petitioner raised a novel issue in the petition for review by certiorari, questioning whether a househelper working in the staff houses of an industrial company should be classified as a mere household helper or as a regular employee of the firm.
    • The petitioner contended that because the respondent’s employment was within the confines of the employer’s staff house, she should be regarded as a domestic helper rather than a regular employee eligible for the full range of employment benefits.

Issue:

    Classification of Employment

    • Is a househelper performing laundry services within the staff houses of an industrial company to be regarded as a domestic helper (or househelper) as defined under Rule XIII, Section 1(b), Book 3 of the Labor Code?
    • Should such a worker instead be classified as a regular employee of the company, thereby entitling her to benefits such as separation pay, salary differentials, and other regular employee privileges?

    Legality of the Dismissal

    • Was the dismissal of Sinclitica Candido—following her inability to work after the accident—justified under existing labor laws?
    • Did the events surrounding the accident and subsequent actions by the employer amount to an illegal or constructive dismissal?

    Applicability of the Labor Code Provisions

    • Does the definition provided in Rule XIII, Section 1(b) of the Labor Code, which defines “househelper” or “domestic servant” as one who works exclusively for the personal comfort and enjoyment of the employer’s family, apply to workers employed in staff houses serving the needs of a company’s guests and employees?
    • How should the nature of the work and the location of employment influence the classification of the worker for purposes of determining entitlement to benefits?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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