Case Digest (G.R. No. 113003) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ariel Espina, Analy Dolojan, Daria Donor, Roel Donor, et al. v. Highlands Camp/Rawlings Foundation, Inc. and Jayvelyn Pascal (G.R. No. 220935 and G.R. No. 219868, decided July 28, 2020), two groups of former employees of Highlands Camp/Rawlings Foundation, Inc. filed complaints with the National Labor Relations Commission (NLRC) in 2011 for illegal dismissal, non-payment of overtime pay, holiday pay, and 13th month pay, claiming moral and exemplary damages. The petitioners, hired since 2000 as cooks, cook helpers, utility workers, and service crew at the camp site in Iba, Zambales, worked regularly from January to June, remained on call from July to September, reported daily during October’s peak season, and returned on call in November and December. Every year from 2001 to 2010, they submitted their biodata, medical clearances, and Social Security numbers for rehire but were informed in 2011 that they would be contacted upon camper arrival—contact that never came. They later Case Digest (G.R. No. 113003) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and nature of the complaint
- Two groups of employees, headed by Randy Dolojan and Edwin Adona, filed complaints on March 24, 2011 against Highlands Camp/Rawlings Foundation, Inc. and its Administrator Jayvelyn Pascal for illegal dismissal, non-payment of overtime, holiday and 13th month pay, and moral and exemplary damages.
- Petitioners claimed tenure from 2000 to 2010 as cooks, cook helpers, utility workers, and service crew at Highlands’ camping site in Iba, Zambales.
- Employment pattern and termination
- From 2000 to 2010, petitioners:
- Regularly worked January to June;
- Were “on call” July to September;
- Worked daily in October (peak season);
- Were on call in November/December depending on camper volume.
- Annually submitted rehire requirements; in 2011 they were not rehired and discovered replacement by new hires.
- Procedural history
- Labor Arbiter (Jan 16, 2013) – Found petitioners regular employees; illegal dismissal; awarded separation pay (in lieu of reinstatement), backwages, 13th month pay, and 10% attorney’s fees; denied holiday/overtime pay and moral/exemplary damages.
- NLRC (July 31, 2013) – Affirmed with modification; added holiday pay; set aside computation; denied motion for reconsideration (Oct 30, 2013).
- Court of Appeals (May 15, 2015) – Reversed; held petitioners seasonal employees; dismissed the complaint; denied reconsideration (July 29, 2015).
- Petitioners elevated the consolidated case to the Supreme Court.
Issues:
- Employment status
- Were petitioners seasonal employees or regular employees of Highlands Camp?
- Validity of termination
- Did petitioners’ end-of-season non-rehiring constitute illegal dismissal?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)