Case Digest (G.R. No. 200555) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pedro D. Dusol and Maricel M. Dusol v. Emmarck A. Lazo, G.R. No. 200555, decided January 20, 2021, petitioners Pedro and Maricel Dusol filed a complaint for illegal dismissal, underpayment of benefits, damages, and attorney’s fees against respondent Emmarck Lazo, owner of Ralco Beach resort. Pedro began working on January 6, 1993 as sole caretaker of the beach, cleaning and securing cottages, rest houses, the store, and entertaining guests from 5 a.m. to 9 p.m. daily for a weekly allowance initially of ₱100 later increased to ₱239. In 1995, he also entered a fishpond venture with Lazo’s parents for two harvests but returned exclusively as caretaker after its closure. In 2001 Maricel was engaged to manage the resort store for a ₱1,000 monthly allowance plus 15% commission on rentals, working identical hours. In July 2008 Lazo informed them he would lease out the resort, rendering their services unnecessary. They stopped work and filed before the Labor Arbiter (LA), submitting Case Digest (G.R. No. 200555) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Dispute
- Petitioners Pedro and Maricel Dusol filed a complaint for illegal dismissal, underpayment of benefits, damages, and attorney’s fees against respondent Emmarck A. Lazo, owner of Ralco Beach resort.
- Petitioners claimed employer-employee relationship: Pedro as sole caretaker (1993–2008) working 5 a.m. to 9 p.m. daily for weekly allowance (₱100 rising to ₱239), and Maricel as store manager (2007–2008) for monthly ₱1,000 plus 15% commission.
- Respondent’s Defense
- Emmarck and his parents alleged that Pedro and Maricel were industrial partners, not employees, in both a fishpond business (1995–1996) and the resort: sharing profits and receiving allowances/commissions.
- They emphasized no power to dismiss partners, no supervision or guidelines over their work, and free residence on the property.
- Proceedings Below
- Labor Arbiter (Jan. 26, 2009): Dismissed complaint for lack of proof of employment (no demonstration of control, time records, or that payments were wages).
- NLRC (Aug. 27 & Oct. 30, 2009): Reversed LA, applied four-fold test, found employment relationship, declared dismissals illegal, and awarded separation pay, nominal damages, wage differentials, 13th-month pay, and attorney’s fees.
- Court of Appeals (May 23, 2011; Jan. 27, 2012): Reinstated LA decision, held no employer-employee relationship due to lack of control, granted certiorari for CA’s review.
- Supreme Court petition: Petitioners sought review under Rule 45 to challenge CA’s findings.
Issues:
- Whether Pedro and Maricel were employees of Emmarck or his industrial partners.
- If employees, whether their termination was valid or illegal for lack of procedural due process.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)