Case Digest (G.R. No. 192084) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose Mel Bernarte v. Philippine Basketball Association (PBA), Jose Emmanuel M. Eala, and Perry Martinez, G.R. No. 192084, decided on September 14, 2011 under the 1987 Constitution, petitioner Bernarte and co-complainant Guevarra were basketball referees engaged by the PBA through successive *contracts of retainer* from 2001 to 2003. Bernarte signed a one-and-a-half-month contract (July 1–August 5, 2003) and received a non-renewal letter dated January 15, 2004, citing unsatisfactory performance. He alleged dismissal was retaliatory after he refused to fix games. Guevarra similarly entered into yearly contracts from 2002 until he was not rehired in February 2004. Both filed illegal dismissal cases before the Labor Arbiter, who on March 31, 2005 ruled they were employees illegally dismissed and ordered reinstatement with backwages, damages, and attorney’s fees. The NLRC affirmed on January 28, 2008. The PBA filed a certiorari petition before the Court of Appeals (CA-G.R. SP No. Case Digest (G.R. No. 192084) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Engagement and Contracts of Referees
- Jose Mel Bernarte
- Invited to join PBA as referee under Commissioner Bernardino on year-to-year contracts.
- First conference (Feb–Jun 2003) worked without contract; second conference (Jul 1–Aug 5, 2003) signed a 1½-month retainer.
- On Jan 15, 2004 received letter of non-renewal citing unsatisfactory performance; alleged actual cause was refusal to fix a game.
- Renato Guevarra
- Invited Feb 2001; signed trainee contract Mar 1, 2001; from 2002 onward yearly contract as Regular Class C referee.
- May 6, 2003 received memorandum of dissatisfaction; from Feb 2004 no further contract offered.
- Respondents’ Position
- PBA entered into two fixed-term retainer contracts in 2003 (Jan–Jul and Sep–Dec).
- Non-renewal at end of contract periods, exercise of prerogative to hire fixed-term contractors.
- Proceedings Below
- Labor Arbiter (Mar 31, 2005)
- Held Bernarte and Guevarra were employees illegally dismissed.
- Ordered reinstatement, backwages, moral/exemplary damages, attorney’s fees.
- National Labor Relations Commission (Jan 28, 2008)
- Affirmed Labor Arbiter’s decision; dismissed PBA’s appeal.
- Court of Appeals (Dec 17, 2009 Decision; Apr 5, 2010 Resolution)
- Granted PBA’s petition for certiorari; annulled NLRC and Labor Arbiter rulings.
- Held referees were independent contractors; dismissed complaint.
Issues:
- Procedural Issue
- Whether the Labor Arbiter’s Decision became final and executory by constructive service via unclaimed registered mail.
- Substantive Issue
- Whether Jose Mel Bernarte was an employee of the PBA or an independent contractor, and consequently, whether his non-renewal constituted illegal dismissal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)