Case Digest (G.R. No. 195466) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In January 2009 respondent John G. Macasio, who alleged he had worked as a butcher since January 6, 1995, filed a complaint before the Labor Arbiter against petitioner Ariel L. David, doing business under the name and style Yiels Hog Dealer in Sta. Mesa, Manila. He claimed nonpayment of overtime, regular and special holiday pay, service incentive leave (SIL), 13th month pay, moral and exemplary damages, and attorney’s fees. Macasio asserted that David exercised supervision and control over his work schedule, tools, and leaves, and owned the hogs he chopped. David countered that Macasio was engaged on a pakyaw or task basis at a fixed P700 per engagement, that no employer-employee relationship existed, and that Macasio had freedom to report for work. On April 30, 2009 the Labor Arbiter dismissed the complaint for lack of merit, finding a task-basis engagement; on May 26, 2010 the NLRC affirmed; and on November 22, 2010 the Court of Appeals in CA-G.R. SP No. 116003 reversed, grant Case Digest (G.R. No. 195466) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Dispute
- In January 2009, respondent John G. Macasio filed before the Labor Arbiter (LA) a complaint against petitioner Ariel L. David (doing business as Yiels Hog Dealer) for non-payment of overtime, holiday pay, service incentive leave (SIL), 13th month pay, moral and exemplary damages, and attorney’s fees.
- Macasio alleged he had worked as a butcher since January 6, 1995 under David’s control (work hours, tools, job assignments, leave approvals), receiving a daily wage increased over the years from ₱400 (2005) to ₱700 (2009); David owned the hogs, tools and rented the workplace.
- Defense and Evidence
- David contended his hog-dealing business only began in 2005, engaged Macasio on a pakyaw (task) basis: paid ₱700 per engagement (regardless of hours or hog volume), worked typically 10:00 p.m.–2:00 a.m., no pay when no hogs delivered, and only 10 employees in his employ.
- Macasio disputed the task-basis claim, argued daily reporting (payroll/time records would show), and pointed to a Certificate of Employment (erroneously dated 2000). David presented a “Pinagsamang Sinumpaang Salaysay” by two co-butchers corroborating the task basis.
- Proceedings Below
- LA Decision (April 30, 2009): Dismissed the complaint, finding pakyaw engagement and thus excluded from overtime, holiday, SIL and 13th month pay.
- NLRC Ruling (May 26, 2010; Reconsideration denied August 11, 2010): Affirmed the LA, holding that Macasio was paid by result (task basis) and thus not covered by the relevant labor-standard laws.
- CA Decision (November 22, 2010; Reconsideration denied January 31, 2011): Reversed the NLRC for grave abuse of discretion—while agreeing on task basis, held Macasio was not “field personnel” under Serrano v. Severino Santos Transit and thus entitled to holiday, SIL and 13th month pay for three years plus 10% attorney’s fees; denied moral damages.
- Petition for Review
- David filed a Rule 45 petition before the Supreme Court, reiterating task-basis engagement negates employment relationship and statutory benefits.
- Macasio argued the petition raised factual issues (not reviewable in Rule 45), maintained his status as an employee, and cited prior rulings in an illegal-dismissal case affirming the employer-employee relationship.
Issues:
- Did the Court of Appeals correctly find that the NLRC gravely abused its discretion by denying Macasio’s claims for holiday pay, SIL, and 13th month pay solely because of his pakyaw (task)‐basis engagement?
- Does Macasio qualify as “field personnel” under Labor Code Article 82—thus exempting him from holiday and SIL pay?
- Does task‐basis engagement alone exclude an employee from 13th month pay under PD No. 851 and its Implementing Rules?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)