Case Digest (G.R. No. 229326)
Facts:
The case involves petitioners Romina N. Bismonte, Jennifer P. Dacillo, Erwin C. Formentos, Johnny M. Narzoles, Lanie L. Latombo, Enrique C. Hernandez, Nelson G. Bismonte, and Michael S. Villanueva (collectively referred to as "petitioners") against respondents Golden Sunset Resort and Spa and Ricardo "Ricky" Reyes (collectively referred to as "respondents"). The events leading to the case unfolded when the petitioners were hired by the respondents at different times to perform various roles at the resort, including housekeepers, maintenance personnel, waiters, spa attendants, cooks, dishwashers, and concierges.
Three of the petitioners claimed they were dismissed without just cause and without due process, while five others argued they were constructively dismissed due to a significant reduction in their work schedule from six days to three days a week, which adversely affected their income. Additionally, the petitioners alleged that they were...
Case Digest (G.R. No. 229326)
Facts:
Employment and Allegations:
- Petitioners were hired by respondents (Golden Sunset Resort and Spa and Ricardo "Ricky" Reyes) as resort staff, including roles such as housekeepers, maintenance personnel, waiters, spa and massage attendants, cooks, dishwashers, and concierges.
- Three petitioners claimed they were dismissed without just cause or due process.
- Five petitioners alleged constructive dismissal due to a reduction in their work schedule from six to three days a week, leading to a significant income reduction.
- Petitioners also accused respondents of failing to pay entitled benefits, such as holiday pay, overtime pay, service incentive leave pay, and their share of the service charge.
Respondents' Defense:
- Respondents argued that petitioners were not regular employees but seasonal workers.
- They claimed that during lean seasons (e.g., rainy seasons), they reduced workers' duties or allowed them to seek other employment.
- Respondents likened their engagement to an "independent contractorship," asserting they had no control over petitioners' work performance.
Labor Arbiter (LA) Ruling:
- The LA dismissed the complaints, ruling that no employer-employee relationship existed. The LA found that petitioners failed to prove respondents had control over their work performance or the means and methods of their jobs.
National Labor Relations Commission (NLRC) Ruling:
- The NLRC reversed the LA's decision, finding that petitioners were regular employees based on:
- Issuance of company identification cards.
- Certifications stating petitioners were employees.
- The nature of their work being necessary and desirable to respondents' business.
- However, the NLRC ruled that three petitioners failed to prove actual dismissal, and the reduction of workdays for five petitioners did not constitute constructive dismissal due to valid reasons (rainy season).
- The NLRC ordered respondents to pay petitioners P1,076,833.50 for salary differentials, holiday pay, service incentive leave pay, and 13th month pay.
Court of Appeals (CA) Ruling:
- The CA annulled the NLRC decision, reinstating the LA's ruling.
- The CA found that petitioners filed their appeal to the NLRC one day late (April 2, 2014, instead of March 31, 2014).
- The CA also criticized petitioners' counsel for using registered mail instead of personal filing, given the proximity of their office to the NLRC.
Issue:
- Whether the CA correctly ruled that petitioners failed to comply with filing and service requirements for their appeal to the NLRC.
- Whether the CA correctly ruled that petitioners' appeal to the NLRC was filed out of time.
Ruling:
The Supreme Court granted the petition, ruling in favor of petitioners.
Filing and Service Requirements:
- The Court held that while petitioners failed to provide a written explanation for using registered mail, the NLRC's acceptance of the appeal justified relaxing the procedural rules.
- The appeal was meritorious, as evidenced by the NLRC's decision modifying the LA's ruling on the existence of an employer-employee relationship and money claims.
Timeliness of Appeal:
- The Court found that petitioners' appeal was filed on time. The post office stamp on the envelope showed the appeal was mailed on March 31, 2014, the last day for filing.
- A certification from the postmaster confirmed the mailing date, supporting the timeliness of the appeal.
The Court remanded the case to the CA for resolution on the merits, as the CA had not addressed the substantive issues.
Ratio:
- (Unlock)