Case Digest (G.R. No. 132601) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 246892, decided on September 21, 2022 under the 1987 Constitution, petitioners Chrisden Cabrera Ditiangkin, Hendrix Masamayor Molines, Harvey Mosquito Juanio, Joselito Castro Verde, and Brian Anthony Cubacub Nabong were engaged by respondent Lazada E-Services Philippines, Inc. in February 2016 as delivery riders. Each signed an Independent Contractor Agreement for one year at a daily service fee of ₱1,200.00, using their own motorcycles to collect goods from sellers and transport them to Lazada’s warehouse. In January 2017 a dispatcher informed them that they had lost their usual routes; despite reporting for duty over three days, they received no assignments and later learned their schedules had been reassigned. The riders filed a complaint with the NLRC for illegal dismissal, nonpayment of wages (including overtime, holiday pay, service incentive leave, thirteenth month pay, separation pay), and illegal deductions, seeking moral and exemplary damages and attorney’s Case Digest (G.R. No. 132601) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Engagement and Contractual Terms
- In February 2016, Chrisden Cabrera Ditiangkin, Hendrix Masamayor Molines, Harvey Mosquito Juanio, Joselito Castro Verde, and Brian Anthony Cubacub Nabong (collectively, petitioners/riders) were engaged by Lazada E-Services Philippines, Inc. (Lazada) to pick up items from sellers and deliver them to Lazada’s warehouse.
- Each rider signed an Independent Contractor Agreement stating:
- A one-year term of engagement.
- A service fee of ₱1,200.00 per day.
- Responsibility to use their own motorcycles.
- Removal from Routes and Labor Proceedings
- In January 2017, a dispatcher informed the riders they would be removed from their usual routes. They reported for work for three days but received no assignments; routes were reassigned to others.
- The riders filed a complaint before the National Labor Relations Commission (NLRC) for illegal dismissal and non-payment of salary, overtime, holiday pay, service incentive leave pay, 13th-month pay, separation pay, illegal deductions, moral and exemplary damages, and attorney’s fees—claiming they were regular employees under Lazada’s control.
- Lazada maintained the riders were independent contractors; delivery was ancillary to its main business (an online marketplace).
- The Labor Arbiter dismissed the complaint for lack of employer-employee relationship, relying on the Independent Contractor Agreement and finding no control over means and methods of work.
- The NLRC affirmed; its denial of reconsideration was followed by a Court of Appeals (CA) outright dismissal of the riders’ Rule 65 certiorari petition for using the wrong procedural remedy (should have been Rule 43). The CA denied reconsideration.
- Petitioners elevated the case to the Supreme Court via a Petition for Review under Rule 45.
Issues:
- Whether the Court of Appeals erred in dismissing the certiorari petition outright instead of entertaining it under Rule 65.
- Whether petitioners are regular employees of Lazada, to wit:
- Whether they are independent contractors.
- Whether they satisfy the four-fold test.
- Whether there is economic dependence in their engagement.
- Whether petitioners are entitled to monetary awards (backwages, benefits, separation pay, damages, attorney’s fees).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)