Case Digest (G.R. No. 215874)
Facts:
Arlo Aluminum, Inc. v. Vicente M. Pinon, Jr., G.R. No. 215874, July 05, 2017, the Supreme Court Second Division, Mendoza, J., writing for the Court.Petitioner Arlo Aluminum, Inc. contracted to supply and install aluminum and glass works for the Eton Residences Greenbelt project and subcontracted the glazing work to E.M. Pinon Glazing (EMP Glazing). Respondent Vicente M. Pinon, Jr. filed suit in behalf of his deceased son, Vic Edward Pinon, one of eleven EMP Glazing workers who perished when a gondola fell from the 32nd floor on January 27, 2011.
After the accident, Eton Properties and Arlo Aluminum extended financial assistance of P150,000 to each family; funeral, burial expenses and SSS contributions for Vic Edward were also paid. Vicente signed a Deed of Release, Waiver and Quitclaim dated February 3, 2011, which expressly stated that the P150,000 constituted payment for unpaid salaries and benefits of Vic Edward and released the listed companies from any claims related to the accident.
On May 3, 2011, Vicente filed a complaint before the Labor Arbiter (LA) for underpayment of wages and related benefits and for death/damage claims. Arlo Aluminum maintained that Vic Edward was an EMP Glazing employee and that Arlo Aluminum and Eton Properties were not liable; it also relied on the signed quitclaim as settlement and proof of satisfaction. A DOLE-NCR inspection found that Vic Edward was not an employee of Eton Properties; Arlo Aluminum argued it was not among contractors cited for unpaid obligations.
The LA (Nov. 22, 2011) found EMP Glazing to be the direct employer but awarded Vicente unpaid salary differentials, service incentive leave pay and 13th month pay against EMP Glazing, and dismissed the complaint against Eton Properties and Arlo Aluminum for lack of merit. The NLRC (June 29, 2012) modified the LA decision, finding that, under Article 106 of the Labor Code, principal contractor, contractor and subcontractor (Eton Properties, Arlo Aluminum, and EMP Glazing) were solidarily liable for unpaid wages when a subcontractor fails to pay; it affirmed the LA’s computation (P145,276.22) and ordered joint and several payment. The NLRC denied reconsideration (Sept. 19, 2012).
Arlo Aluminum petitioned the Court of Appeals (CA) by certiorari. The CA (Feb. 11, 2014) affirmed the NLRC: it declared the quitclaim invalid because signed shortly after the death while Vicente was alleged to be overwrought, found EMP Glazing to be a labor-only contractor (insufficient capital/investment), and held the partie...(Pro-only)
Issues:
- Is the Deed of Release, Waiver and Quitclaim executed by Vicente valid and enforceable against his complaint for unpaid wages and benefits?
- If the quitclaim is invalid, must the P150,000 received be returned or offset against any labor award?
- Did the CA err in deciding factual matters (e.g., that EMP Glazing was a labor-only contractor) not properly raised for review and beyond the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)