Case Digest (G.R. No. 249737) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case at hand is Edita Santos Degamo vs. My Citihomes (Citihomes Builder & Development Corporation), John Wang, and Rosie Wang, adjudicated by the Supreme Court of the Philippines, with a ruling dated September 15, 2021 (G.R. No. 249737). The controversy began when Edita Santos Degamo (the petitioner) filed a complaint on December 28, 2017, against My Citihomes alleging non-payment of commission fees. Degamo contended that she was hired as an agent by Citihomes on March 1, 2015, and subsequently promoted to sales manager with specific responsibilities that included soliciting potential buyers, advising clients, supervising property consultants, and reporting to the Citihomes office. However, due to low sales, she resigned effective April 30, 2017, but her resignation was not accepted. Furthermore, Citihomes failed to pay her commissions for 18 properties she had sold. In response, Citihomes denied her claims, asserting that she was merely an independent sales agent under
Case Digest (G.R. No. 249737) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Edita Santos Degamo, who filed a complaint for non-payment of commission fees.
- Respondents:
- My Citihomes (Citihomes Builder & Development Corporation), a domestic corporation engaged in real property development and construction.
- John Wang and Rosie Wang, the owners of Citihomes.
- Employment Allegations and Engagement
- Petitioner was allegedly hired by Citihomes on March 1, 2015 to work in Citi Pro, a group of real estate agents under Citihomes.
- Following her hiring, she was promoted to sales manager with tasks that included:
- Soliciting potential clients for the purchase or sale of real properties.
- Advising clients regarding prices, conditions, and other related details.
- Supervising property consultants.
- Manning Citihomes’ or Citi Pro’s booths.
- Reporting directly to the office of Citihomes.
- Petitioner’s Position:
- She maintained that she was a regular employee of Citihomes, subject to its rules, regulations, and work monitoring (three times a week from 9:00 a.m. to 6:00 p.m.).
- She claimed that Citihomes imposed a monthly sales quota of P5,000,000.00, which indicated the company’s control over her work.
- Her claim for commission fees was based on the sales of 18 real properties.
- Dispute Over Commission Fees
- On December 28, 2017, petitioner filed a Complaint for non-payment of commission fees.
- Petitioner alleged that despite having successfully sold several real properties, Citihomes refused to pay her due commissions.
- She also sought moral and exemplary damages for the alleged wrong done.
- Procedural History and Tribunal Rulings
- Labor Arbiter’s Decision (October 4, 2018):
- Found the in-house broker, Ms. Evelyn Abapo, to have acted as a labor-only contractor.
- Ruled that Citihomes was de facto the employer of petitioner and ordered payment of commissions for 10 accounts amounting to P117,121.21.
- Denied petitioner’s claim for damages due to lack of factual and legal basis.
- NLRC Proceedings:
- Both parties appealed before the NLRC.
- In its Decision dated December 21, 2018, the NLRC set aside the Labor Arbiter’s findings.
- The NLRC ruled that no employer-employee relationship existed between Citihomes and petitioner, as her engagement was through independent brokerage arrangements.
- Petitioner’s subsequent motion for reconsideration was denied in the NLRC Resolution dated February 28, 2019.
- Court of Appeals (CA) Decision (October 1, 2019):
- Dismissed petitioner’s petition for certiorari.
- Affirmed that the NLRC did not gravely abuse its discretion in holding there was no employer-employee relationship.
- Supreme Court Petition:
- Petitioner challenged the CA ruling, contending errors in assessing the employer-employee relationship based on the four-fold test.
- Parties’ Positions on Employment Relationship
- Citihomes’ Argument:
- Petitioner was not its direct employee but an independent contractor engaged through its licensed real estate broker, Ms. Abapo.
- The payment of commissions did not equate to wage payment.
- Petitioner maintained substantial independence regarding her methods and operations, as typical in real estate brokerage arrangements.
- Petitioner’s Argument:
- Asserted that she was directly hired by Citihomes, and that the company controlled her work hours, methods, and imposed specific sales targets.
- Claimed that such control, including the power to dismiss her, clearly established an employer-employee relationship.
Issues:
- Primary Issue
- Whether an employer-employee relationship existed between Citihomes and petitioner.
- Specific Considerations
- Whether the four essential elements (the selection and engagement, payment of wages, the power to dismiss, and the control over work methods) were present.
- Whether petitioner’s commission-based compensation and her engagement through Ms. Abapo signify an employment relationship or an independent contractor status.
- The admissibility and sufficiency of the evidence submitted by the petitioner to prove direct employment by Citihomes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)