Title
Supreme Court
Atlanta Industries, Inc. vs. Sebolino
Case
G.R. No. 187320
Decision Date
Jan 26, 2011
Workers claimed illegal dismissal after apprenticeship; SC ruled agreements invalid, prior employment proven, and dismissals unlawful.

Case Digest (G.R. No. 187320)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Several workers – including Aprilito R. Sebolino, Khim V. Costales, Alvin V. Almoite, Joseph S. Sagun, among others – filed complaints in February and March 2005 alleging illegal dismissal, nonpayment of wages, underpayment, and other money claims.
    • The complaints also included claims for regularization, moral and exemplary damages, and attorney’s fees against Atlanta Industries, Inc. and its President/COO, Robert Chan.
  • Nature of the Employment Relationship and Alleged Regularization
    • The complainants asserted that by having worked for more than six (6) months under a purported apprenticeship agreement, they had attained regular employee status.
    • They contended that their dismissal at the end of the apprenticeship period was illegal because, in their view, the apprenticeship was a cover to circumvent the granting of regular employment.
    • In response, Atlanta Industries and Robert Chan maintained that the workers were hired as apprentices under a government-approved program and not as regular employees.
  • Procedural History and Arbitration Proceedings
    • The multiple complaints were consolidated and raffled to Labor Arbiter Daniel Cajilig, later transferred to Labor Arbiter Dominador B. Medroso, Jr.
    • On April 24, 2006, the labor arbiter dismissed the complaint for four of the workers (dela Cruz, Magalang, ZaAo, and Chiong) while ruling the termination of the remaining nine as illegal, awarding them backwages and other claims.
    • Atlanta appealed the labor arbiter’s decision to the National Labor Relations Commission (NLRC), and in the meantime, some complainants entered into a compromise agreement with the company.
    • The NLRC decision on December 29, 2006, modified the labor arbiter’s findings by:
      • Withdrawing the illegal dismissal finding for some complainants.
      • Maintaining the dismissal of complaints for others.
      • Approving the compromise agreement for a subset of workers, while denying all other claims.
    • After unsuccessful motions for reconsideration before the NLRC, Sebolino, Costales, Almoite, and Sagun petitioned the Court of Appeals under Rule 65, alleging grave abuse of discretion.
  • Evidence on Prior Employment and Apprenticeship Agreements
    • The CA’s findings relied heavily on operational documents such as:
      • The CPS Monthly Report for December 2003, used to establish that Costales and Almoite were already working for Atlanta.
      • The Production and Work Schedule for March 7–12, 2005, showing that Sebolino and Sagun were scheduled to work, thereby attesting to their status as employees before entering into apprenticeship agreements.
    • The petitioners, however, defended their position by emphasizing the Master List (prepared by the company accountant) which allegedly contained only names of those employed by Atlanta.
    • The CA found the Master List unreliable due to its legibility issues and internal inconsistencies, noting that it did not reflect the employment records shown by the other documents.
  • Other Pertinent Facts
    • The apprenticeship agreements executed by the workers were under dispute because:
      • They were allegedly defective for not indicating the trade or occupation for training.
      • They did not have proper approval from the Technical Education and Skills Development Authority (TESDA) as required by law.
    • Some workers (Ramos, Alegria, Villagomez, Costales, and Almoite) had entered into a compromise agreement with Atlanta; however, Costales and Almoite later challenged its validity on the grounds that they did not sign it.
    • Petitioners contended that the workers’ tenure ended with the completion of their apprenticeship and thus no regular employer-employee relationship had been established.

Issues:

  • Whether the respondent workers were already employees of Atlanta Industries, Inc. before they were engaged as apprentices.
  • Whether the apprenticeship agreements executed with the respondents were valid and compliant with the legal requirements, including TESDA approval and proper indication of trade or occupation.
  • Whether the dismissal of the respondents, given their prior employment status and the alleged defectiveness of the apprenticeship agreements, amounted to an illegal dismissal under the Labor Code.
  • Whether the compromise agreement entered into by some of the workers is binding on all parties, particularly on those who did not sign it.
  • Whether the procedural requirements under Section 4, Rule 45 of the Rules of Court, concerning the attachment of material documentary evidence (such as the Production and Work Schedule and the compromise agreement) were satisfied in the petition.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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