Case Digest (G.R. No. 187320)
Facts:
Atlanta Industries, Inc. and/or Robert Chan v. Aprilito R. Sebolino, Khim V. Costales, Alvin V. Almoite, and Joseph S. Sagun, G.R. No. 187320, January 26, 2011, Supreme Court Third Division, Brion, J., writing for the Court.In February–March 2005, a group of workers led by Aprilito R. Sebolino, Khim V. Costales, Alvin V. Almoite and Joseph S. Sagun (and others) filed consolidated complaints for illegal dismissal, regularization, underpayment and other money claims against employer Atlanta Industries, Inc. (Atlanta) and its President Robert Chan. Atlanta, a manufacturer of steel/plastic building materials, defended that the workers were apprentices under government‑approved apprenticeship arrangements and therefore not entitled to regularization or related claims; the company also produced a Master List of employees purportedly showing the workers were not regular employees prior to apprenticeship.
The consolidated cases were raffled initially to Labor Arbiter Daniel Cajilig and later transferred to Labor Arbiter Dominador B. Medroso, Jr. On April 24, 2006, the labor arbiter dismissed some complaints but found the termination of nine workers (including the four principal respondents) illegal and awarded aggregate monetary relief of P1,389,044.57. Atlanta appealed to the National Labor Relations Commission (NLRC).
On December 29, 2006, the NLRC modified the labor arbiter’s rulings: it withdrew illegal‑dismissal findings as to several employees, affirmed dismissals as to others, approved a compromise agreement as to Costales, Ramos, Villagomez, Almoite and Alegria, and denied remaining claims. The NLRC denied reconsideration on March 30, 2007. Four aggrieved respondents (Sebolino, Costales, Almoite and Sagun) filed a petition for certiorari under Rule 65 with the Court of Appeals (CA), alleging grave abuse of discretion by the NLRC in not recognizing prior employment, in validating the second apprenticeship agreement, in finding some dismissals legal, and in upholding the compromise agreement.
The CA (CA‑G.R. SP No. 99340; decision penned by Abarintos, J.) granted the petition. The CA found the four were company employees before apprenticeship (relying on a CPS monthly report and production/work schedules), held the first and second apprenticeship agreements defective for failing to indicate the trade and for lack of TESDA approval, concluded the four occupied positions indispensable to the business (thus regular employees) and were illeg...(Subscriber-Only)
Issues:
- Was the petition for review defective for failing to attach material portions of the record (the Production and Work Schedule and the purported compromise agreement) under Section 4, Rule 45 of the Rules of Court?
- Were Costales, Almoite, Sebolino and Sagun already employees of Atlanta before they were engaged as apprentices?
- Were the apprenticeship agreements entered into with the respondents valid under Article 61 of the Labor Code and its implementing rules?
- Were the respondents’ terminations illegal under the Labor Code?
- Is the compromise agreement binding on Costales a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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