Title
Atienza vs. Saluta
Case
G.R. No. 233413
Decision Date
Jun 17, 2019
Driver claimed illegal dismissal by CRV Corp. after accident; SC ruled he was petitioner’s personal driver, not CRV employee, denying monetary claims due to lack of employer-employee proof.
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Case Digest (G.R. No. 233413)

Facts:

Employment and Accident:
Noel Sacramento Saluta (respondent) claimed he was hired as a company driver by CRV Corporation in May 2012, with a monthly salary of P9,000.00. He was assigned to drive for Celia R. Atienza (petitioner), a top official of the company. On December 11, 2014, respondent was involved in a vehicular accident while driving along the North Luzon Expressway. He was made to pay P15,000.00 for damages, which the company advanced but later intended to deduct from his salary. His driver’s license was confiscated, and he was issued a Temporary Operator’s Permit (TOP).

Alleged Termination:
On December 23, 2014, respondent informed petitioner that he needed to claim his driver’s license since his TOP had expired. Petitioner allegedly refused to excuse him, leading respondent to take a leave on December 24, 2014, without reporting for work. Petitioner allegedly told him, "kung hindi ka makakapag-drive ngayon, mabuti pa maghiwalay na tayo," which respondent interpreted as verbal termination. When he went to CRV Corporation, General Manager Rodolfo Reyes confirmed his termination and refused to release his salary due to the pending P15,000.00 reimbursement.

Complaint Filed:
Respondent filed a complaint on April 7, 2015, against CRV Corporation and petitioner for illegal dismissal, non-payment of wages, overtime pay, holiday pay, and other monetary claims.

Petitioner’s Defense:
Petitioner contended that respondent was her personal/family driver, not an employee of CRV Corporation. She claimed respondent abandoned his job when he failed to report for work on December 23, 2014, without permission. Petitioner also stated that respondent admitted fault for the accident and agreed to pay the P15,000.00 damages.

Issue:

  1. Whether an employer-employee relationship existed between respondent and CRV Corporation.
  2. Whether respondent was illegally dismissed or abandoned his job.
  3. Whether respondent is entitled to monetary claims, including backwages, separation pay, and other benefits.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

The Supreme Court reversed the Court of Appeals’ decision and affirmed the Labor Arbiter’s ruling, holding that petitioner was not liable for respondent’s monetary claims, as respondent was her personal/family driver and not an employee of CRV Corporation.
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