Case Digest (G.R. No. 80767) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Boy Scouts of the Philippines v. National Labor Relations Commission (G.R. No. 80767, April 22, 1991), the petitioner, Boy Scouts of the Philippines (“BSP”), is a civic, non‐stock, non‐profit organization created by Commonwealth Act No. 111, as amended by P.D. No. 460. Private respondents Fortunato C. Esguerra, Roberto O. Malaborbor, Estanislao M. Misa, Vicente N. Evangelista and Marcelino P. Garcia were rank‐and‐file employees stationed at the BSP Camp in Makiling, Los Baños, Laguna. By Special Orders dated October 19, 1984, BSP directed their transfer to Davao del Norte effective November 20, 1984. The employees opposed, filed a complaint for illegal transfer with the Ministry of Labor on November 13, 1984, were suspended in late January 1985 for insubordination, and were terminated effective February 15, 1985. They amended their complaint to include illegal dismissal and unfair labor practice. The Labor Arbiter dismissed their complaint on July 31, 1985, but the NLRC rever Case Digest (G.R. No. 80767) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioner Boy Scouts of the Philippines (BSP) is a civic service, non-stock, non-profit organization created by Commonwealth Act No. 111, as amended by P.D. No. 460.
- Private respondents Fortunato C. Esquerra, Roberto O. Malaborbor, Estanislao M. Misa, Vicente N. Evangelista and Marcelino P. Garcia were rank-and-file employees of BSP stationed at the Makiling Camp, Los Baños, Laguna, until February 1985.
- Transfer Orders and Opposition
- On 19 October 1984, BSP’s Secretary-General issued Special Orders Nos. 80, 81, 83, 84 and 85 transferring each respondent to the BSP Land Grant in Asuncion, Davao del Norte, effective 20 November 1984.
- Respondents appealed this transfer to the BSP National President (4 November 1984) and attended a pre-transfer briefing (6 November 1984), where they were promised no salary diminution and a one-month relocation allowance.
- Refusal to Comply and Disciplinary Actions
- On 13 November 1984, respondents filed a complaint for illegal transfer before the Ministry of Labor and Employment, seeking to enjoin implementation of the Special Orders.
- On 21 November 1984, BSP issued memoranda charging respondents with insubordination and warning of administrative sanctions; respondents continued to refuse transfer.
- In late January 1985, BSP suspended respondents for five days; by Special Order dated 12 February 1985, their services were terminated effective 15 February 1985.
- Labor Proceedings and Initial Decisions
- On 22 February 1985, respondents amended their complaint to include illegal dismissal and unfair labor practice charges.
- The Labor Arbiter dismissed the complaint for lack of merit (31 July 1985).
- The NLRC reversed the Arbiter’s decision and ordered reinstatement with full backwages (Decision dated 27 February 1987; Resolution dated 16 October 1987).
- Certification of BSP’s Corporate Status
- BSP consistently alleged in pleadings that it is a “civic service, non-stock and non-profit” entity; respondents likewise called it a “public corporation.”
- On 9 August 1989, the Supreme Court required comments on whether BSP is a government-owned or controlled corporation (GOCC) under Article IX-B(2)(1) of the 1987 Constitution.
- Petitioner and respondents argued BSP is purely private; the Solicitor General and Government Corporate Counsel maintained BSP is a GOCC or quasi-public corporation attached to DECS.
Issues:
- Whether the Boy Scouts of the Philippines is a government-owned or controlled corporation with an original charter, thus embracing its employees within the Civil Service under Article IX-B(2)(1) of the 1987 Constitution.
- Whether the NLRC and the Labor Arbiter had jurisdiction over the private respondents’ labor complaints in NLRC Case No. 1637-84.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)