Case Digest (G.R. No. 173254-55) Core Legal Reasoning Model
Facts:
The case involves Diamond Farms, Inc. (DFI) as the petitioner against Southern Philippines Federation of Labor (SPFL) and various individuals as respondents, with a decision rendered on January 13, 2016 by the Supreme Court. DFI owned an 800-hectare banana plantation located in Alejal, Carmen, Davao, which came under the coverage of the Comprehensive Agrarian Reform Law (Republic Act No. 6657). Despite being granted a deferment to continue operations until 1998 by the Department of Agrarian Reform (DAR), DFI faced operational issues and ultimately laid off a significant number of employees. Workers then petitioned DAR, claiming that DFI had abandoned the plantation, leading to the cancellation of its deferment privilege and the consequent compulsory acquisition of land.
The awarded plantation of 689.88 hectares, sold to the government, was managed by the newly formed Diamond Farms Agrarian Reform Beneficiaries Multi-Purpose Cooperative (DARBMUPCO) on January 1, 1996. DARBMUPCO
Case Digest (G.R. No. 173254-55) Expanded Legal Reasoning Model
Facts:
DFI, owning an 800‐hectare banana plantation in Alejal, Carmen, Davao, originally operated under the Comprehensive Agrarian Reform Law (CARL) with a deferment privilege, experienced operational difficulties that led to a partial closure and layoff of employees. Soon after, DARBMUPCO—organized by agrarian reform beneficiary farmers who took over a portion (689.88 hectares) of the plantation after a Voluntary Offer to Sell to the government—entered into a Banana Production and Purchase Agreement (BPPA) with DFI to cultivate high‐grade export bananas. A Supplemental to Memorandum Agreement (SMA) further provided that DFI would shoulder certain labor-related costs for operations under the BPPA.Due to manpower shortages at DARBMUPCO, DFI engaged respondent–contractors who, in turn, recruited approximately 400 workers (the respondent–workers) to work on the awarded and managed areas of the plantation. Disputes arose when a petition for a certification election was filed by the Southern Philippines Federation of Labor (SPFL) on behalf of these workers, contending that they were employed jointly by DFI and DARBMUPCO. Various agencies and tribunals (the Med-Arbiter, SOLE, NLRC, and CA) reviewed the issue; some initially ruled DARBMUPCO was the employer while others, notably the SOLE and later the Court of Appeals, emphasized that DFI—having hired and exerted control over the respondent–contractors—was the true statutory employer. DFI, however, contended that DARBMUPCO should be considered the employer and that the respondent–contractors were independent. These proceedings culminated in the Supreme Court reviewing the issue regarding who is the statutory employer among DFI, DARBMUPCO, and the labor-only respondent–contractors.
Issues:
- Who among DFI, DARBMUPCO, and the respondent–contractors is the statutory employer of the respondent–workers?
- Is it proper to conduct a certification election for respondent–workers while a petition for certiorari was pending, particularly when the underlying issue is the determination of the true employer?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)