Case Digest (G.R. No. 233846) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Osias I. Corporal, Sr. et al. vs. National Labor Relations Commission and Lao Enteng Company, Inc., the seven petitioners—Osias I. Corporal, Sr., Pedro Tolentino, Manuel Caparas, Elpidio Lacap, Simplicio Pedelos (barbers), and Teresita Flores and Patricia Nas (manicurists)—worked at New Look Barber Shop in Quiapo, Manila, originally a sole proprietorship owned by Vicente Lao. In January 1982, Vicente Lao’s children formed Lao Enteng Company, Inc., which formally took over the shop’s assets and continued operations. The petitioners all remained in service until April 15, 1995, when Trinidad Lao Ong, president of the corporation, informed them that the building had been sold and their services were no longer needed. On April 28, 1995, the petitioners filed a complaint before the NLRC for illegal dismissal, separation pay, non-payment of 13th month pay, salary differentials, and illegal deductions (including P1.00 daily for the sweeper). The Labor Arbiter and, on appeal, the NLR Case Digest (G.R. No. 233846) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Employment Background
- Petitioners: Osias I. Corporal, Sr., Pedro Tolentino, Manuel Caparas, Elpidio Lacap, Simplicio Pedelos (barbers) and Patricia Nas, Teresita Flores (manicurists) employed at New Look Barber Shop, Quiapo, Manila.
- Private respondent: Lao Enteng Company, Inc. (incorporated January 1982, Trinidad Lao Ong as President) successor to Vicente Lao’s single proprietorship.
- Termination of Services
- Upon incorporation, the respondent company took over the assets and continued the barber shop business. Petitioners remained in service until April 15, 1995.
- Petitioners were informed of shop closure due to sale of the building and serious business losses; their services were “no longer needed.”
- Labor Proceedings
- April 28, 1995: Petitioners filed with the NLRC complaint for illegal dismissal, separation pay, nonpayment of 13th month pay, salary differentials (only Nas), illegal deductions, and refund of P1.00 daily sweeper fee.
- Labor Arbiter (Sept. 28, 1996): Dismissed complaint, finding a joint venture and no employer-employee relationship.
- NLRC First Division (Oct. 17, 1996; Mar. 5, 1997): Affirmed dismissal, ruling petitioners were independent contractors.
- Petitioners elevated to the Supreme Court via certiorari.
Issues:
- Existence of Employer-Employee Relationship
- Whether petitioners were independent contractors/joint-venture partners or employees of Lao Enteng Co., Inc. under the four-element and control tests.
- Entitlement to Statutory Benefits
- Whether petitioners are entitled to separation pay under Labor Code Article 283 for cessation of business.
- Whether petitioners are entitled to 13th month pay under applicable law and guidelines.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)