Case Digest (G.R. No. 173254-55)
Facts:
Diamond Farms, Inc. v. Southern Philippines Federation of Labor (SPFL)-Workers Solidarity of DARBMUPCO/Diamond-SPFL, et al., G.R. Nos. 173254-55 & 173263, January 13, 2016, Supreme Court Third Division, Jardeleza, J., writing for the Court.Diamond Farms, Inc. (DFI) owned an 800-hectare banana plantation that was covered by Republic Act No. 6657 (the Comprehensive Agrarian Reform Law). After DAR recalled DFI’s deferment privilege and accepted DFI’s voluntary offer to sell, 689.88 hectares (the “awarded plantation”) were transferred to agrarian reform beneficiaries who organized into Diamond Farms Agrarian Reform Beneficiaries Multi-Purpose Cooperative (DARBMUPCO), while DFI retained about 200 hectares (the “managed area”).
Under a ten-year Banana Production and Purchase Agreement (BPPA) effective March 27, 1996, DARBMUPCO agreed to produce export-quality bananas to be sold exclusively to DFI; a Supplemental Memorandum Agreement (SMA) provided that DFI would shoulder certain labor costs related to operations. Because DARBMUPCO lacked sufficient manpower, DFI engaged the services of various individual contractors (the respondent-contractors), who in turn recruited some 400 farm workers (the respondent-workers). The engagement spawned labor disputes over who was the workers’ employer.
Multiple administrative and quasi-judicial fora adjudicated aspects of the dispute. A Med-Arbiter granted a petition for certification election and declared DARBMUPCO the employer; the Secretary of Labor and Employment (SOLE) modified that finding and declared DFI the employer; the Labor Arbiter (LA) found the respondent-contractors to be labor-only contractors and deemed DFI the statutory employer; the National Labor Relations Commission (NLRC) modified the LA and held DFI and DARBMUPCO jointly liable in proportion to planted areas. SPFL filed unfair labor practice/monetary claims before the NLRC; DARBMUPCO and others pursued certiorari relief before the Court of Appeals (CA). The CA consolidated C.A.-G.R. SP Nos. 53806, 59958 and 61607 and, in a March 31, 2006 Decision (affirmed by CA resolution May 30, 2006), agreed with the SOLE and found DFI to be the statutory employer, dismissing some petitions and granting others as to the NLRC resolutions. DFI filed this Petitio...(Subscriber-Only)
Issues:
- Whether the conduct of a certification election may be carried out despite the pendency of a petition for certiorari challenging prior administrative resolutions.
- Who among DFI, DARBMUPCO, and the respondent-contractors is the statutory employer of th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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