Facts:

• Remegio E. Burnea (petitioner) filed a case against Security Trading Corporation (STC), Nonpareil International Freight and Cargo Services, Inc. (Nonpareil), Far Eastern Knitting Corporation (Far Eastern), and spouses Jose T. Ching and Esperanza R. Ching.
• In February 2005, the spouses Ching hired Burnea as a construction worker for STC.
• After completing a project, Burnea became a stay-in security guard for STC, earning a monthly salary of P8,500.00.
• On March 1, 2010, he was transferred to Far Eastern to secure its property and was granted Authority to Sell the property.
• Following the sale of the property to Nonpareil on November 15, 2013, Burnea received his commission but was informed that his services were no longer needed.
• Burnea returned to his province and filed a complaint on September 25, 2014, against Far Eastern for non-payment of wages and illegal dismissal.
• The complaint was closed due to a similar complaint filed with the National Labor Relations Commission (NLRC) against STC, Nonpareil, Far Eastern, and the spouses Ching.
• The NLRC complaint included claims for underpayment of salary, 13th month pay, and other benefits, but did not explicitly state illegal dismissal.
• The Labor Arbiter (LA) ruled partially in favor of Burnea, awarding certain monetary claims but dismissing the claim for separation pay due to lack of evidence of illegal dismissal.
• Burnea's appeal to the NLRC was denied, and the Court of Appeals (CA) affirmed the NLRC's decision, leading to the current petition for review on certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court denied the petition, affirming the decisions of the Court of Appeals and the NLRC.
• The Court upheld the findings that Burnea failed to prove his entitlement to the claimed monetary benefi...(Unlock)

Ratio:

• The Court reasoned that labor tribunals and the CA correctly found that Burnea did not substantiate his claims for 13th month pay, overtime pay, holiday premium, rest day premium, and night shift differential.
• Burnea's failure to specify amounts and periods of underpayment was critical, as the burden of proof lies with the claimant.
• The Court emphasized that factual findings of labor tribunals are generally binding unless recognized exceptions are present, which were not applicable in this case.
• Regarding illegal dismissal, the Court noted that the labor tribunals and the CA did...continue reading