Case Digest (G.R. No. 243139)
Facts:
In Domingo Naldo, Jr. et al. v. Corporate Protection Services, Phils., Inc., G.R. No. 243139, decided on April 3, 2024, petitioners Domingo Naldo, Jr., Rogelio Benitez, Isidro Alfonso, Jr., Ronaldo Ledda, Bernardo Fabulare, Armando De Luna, and Nelson Villacentino were security guards engaged by respondent Corporate Protection Services, Phils., Inc. (CORPS) between 2005 and 2010 at monthly salaries of ₱15,000.00 to ₱15,300.00. They alleged underpayment due to monthly deductions for “trust fund savings” (₱200.00–₱1,000.00) and cash bond (₱200.00), mandatory 12-hour daily duty including holidays and rest days, without payment of holiday pay, rest-day premium, service incentive leave pay, 13th month pay, or ECOLA. In January 2015 they filed a Request for Assistance under the Single-Entry Approach (SEnA) of DOLE/NCMB, pressing money claims for unpaid wages, contributions, and benefits. During conciliation conferences on March 3 and 10, 2015, CORPS, through Benjamin Sesgundo, offeCase Digest (G.R. No. 243139)
Facts:
- Employment and Conditions
- Petitioners Domingo Naldo, Jr., Rogelio Benitez, Isidro Alfonso, Jr., Ronaldo Ledda, Bernardo Fabulare, Armando De Luna and Nelson Villacentino were security guards of Corporate Protection Services, Phils., Inc. (CORPS), assigned to Tarlac and Cabanatuan City. Hired between October 2005 and February 2010, their latest salaries ranged from ₱15,000 to ₱15,300 per month.
- They worked 12 hours daily—including regular/special holidays and rest days—and alleged nonpayment of overtime, holiday pay, rest‐day premium, service incentive leave pay, 13th-month pay and ECOLA. Monthly deductions of ₱200–₱1,000 (trust fund savings) and ₱200 (cash bond) were also contested.
- Grievance and SEnA Proceedings
- In January 2015, petitioners filed a Request for Assistance (RFA) under DOLE’s Single-Entry Approach (SEnA) for nonpayment/underpayment of wages and statutory benefits.
- On March 3, 2015, CORPS rep Benjamin Sesgundo offered to pay trust fund savings and cash bond. Petitioners refused, demanding full settlement. On March 10, CORPS conditioned issuance of “new” checks on petitioners’ signing of pro forma resignation letters and quitclaims, which petitioners executed under assurances of full payment; they received the same checks covering only trust fund and cash bond. Thereafter, petitioners were barred from returning to work.
- Labor Arbiter, NLRC and CA Proceedings
- April–May 2015: Petitioners filed consolidated NLRC complaints for nonpayment of wages/benefits and constructive illegal dismissal.
- August 28, 2015: Labor Arbiter (LA) dismissed the complaints, finding voluntary resignation and quitclaims.
- December 29, 2015 & February 24, 2016: NLRC granted appeal, set aside LA decision, held no intent to resign but no illegal dismissal, remanded for computation of monetary claims.
- February 15, 2018 & November 8, 2018: Court of Appeals (CA) dismissed certiorari petitions of both parties, affirming NLRC’s remand and orders, and denied reconsideration. Petitioners elevated the case to the Supreme Court.
Issues:
- Are petitioners guilty of forum shopping?
- Are the resignation letters and quitclaims executed during SEnA valid and binding?
- Did the CA err in ruling that petitioners were not constructively dismissed and thus not entitled to backwages, moral/exemplary damages, and attorney’s fees?
- Validity of the resignation letters.
- Entitlement to monetary claims (backwages, damages).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)