Case Digest (G.R. No. 233413) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Celia R. Atienza v. Noel Sacramento Saluta (G.R. No. 233413, June 17, 2019), respondent Saluta filed a complaint with the National Labor Relations Commission (NLRC) on April 7, 2015 against petitioner Atienza and CRV Corporation for illegal dismissal, non-payment of wages and various benefits, illegal deduction, and issuance of a certificate of employment. Saluta alleged that he was hired as a company driver by CRV Corporation in May 2012 and assigned to drive for Atienza at a monthly salary of ₱9,000. On December 11, 2014, Saluta was involved in a vehicular accident; CRV advanced ₱15,000 for damages to be deducted from his salary. After his temporary permit expired on December 23, 2014, Saluta requested leave to renew his license but was refused by Atienza. He was then told by Atienza that they might as well “separate,” and CRV’s general manager confirmed his termination that afternoon. Saluta’s request for his last salary was denied pending reimbursement of the ₱15,000 adva Case Digest (G.R. No. 233413) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- The respondent, Noel Sacramento Saluta, filed before the NLRC a complaint for illegal dismissal, non-payment of wages, overtime, holiday and rest-day pay, illegal deductions, and issuance of a certificate of employment against CRV Corporation and petitioner Celia R. Atienza.
- The Labor Arbiter (LA) dismissed the illegal dismissal claim, ruled respondent was petitioner’s personal driver under Civil Code Articles 1689, 1697, 1699, and granted only the illegal deduction and certificate of employment claims.
- On appeal, the NLRC reversed the LA, finding an employer-employee relationship with CRV Corporation and illegal dismissal, awarding backwages, separation pay, wage differentials, holiday pay, 13th month pay, and service incentive leave pay, but denying overtime and premium pay claims.
- The CA, via Decision (Apr. 21, 2017), affirmed the NLRC’s finding of illegal dismissal, imposed 6% interest on monetary awards, and denied motion for reconsideration (Aug. 9, 2017). Petitioner then filed this Petition for Review on Certiorari before the Supreme Court.
- Parties’ Allegations
- Respondent’s Version
- Hired in May 2012 by CRV Corporation as a company driver assigned to petitioner, with P9,000/month salary, paid through ATM.
- Incurred a P15,000 advance for vehicular accident damage in December 2014, to be deducted from salary.
- Absent December 24, 2014 to renew license; petitioner allegedly verbally dismissed him “mabuti pa maghiwalay na tayo.” Confirmed terminated by the company’s GM. He was refused his last salary.
- Filed complaint April 7, 2015 asserting illegal dismissal and related claims.
- Petitioner’s Version
- Respondent was her personal/family driver, not a company employee; received free board and lodging plus P9,000/month through the company’s GM.
- Loaned respondent P15,000 for accident damages; he agreed to repay.
- Respondent left December 23, 2014 without permission to renew license, then informed he would not return and asked the company for his salary.
- Denied illegal dismissal, alleged abandonment.
Issues:
- Whether respondent proved an employer-employee relationship with CRV Corporation.
- Whether respondent established he was dismissed from employment.
- Whether respondent validly abandoned his work.
- What legal regime governs family/personal drivers and their claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)