Title
1st Philippine Industrial Corp. vs. Calimbas
Case
G.R. No. 179256
Decision Date
Jul 10, 2013
The Supreme Court ruled in favor of employees Raquel Calimbas and Luisa Mahilom, declaring them as employees of First Philippine Industrial Corporation (FPIC) and entitled to reinstatement and monetary benefits due to their unlawful dismissal by FPIC.
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Case Digest (G.R. No. 179256)

Facts:

  • First Philippine Industrial Corporation (FPIC) is a domestic corporation involved in transporting petroleum products via pipeline.
  • On March 29, 1993, FPIC entered into a Contract of Special Services with De Guzman Manpower Services (DGMS) for clerical, maintenance, and utility services.
  • Raquel Calimbas and Luisa Mahilom were hired by DGMS to perform secretarial and clerical duties for FPIC, starting on February 13, 1996, and June 3, 1996, respectively.
  • On June 21, 2001, FPIC informed Calimbas and Mahilom that their services would no longer be required by July 31, 2001, due to a "Pace-Setting" Study.
  • DGMS formally notified them of the termination of their work assignments with FPIC, citing the end of the Project Contract.
  • Both Calimbas and Mahilom signed quitclaims on August 3, 2001, releasing DGMS from any claims after receiving sums of P17,343.10 and P23,459.14, respectively.
  • Despite the quitclaims, Calimbas and Mahilom filed a complaint against FPIC for illegal dismissal and monetary benefits, alleging they were regular employees of FPIC and were dismissed without cause.
  • The Labor Arbiter ruled in their favor, declaring their dismissal illegal and ordering FPIC to reinstate them and pay back wages and attorney's fees.
  • FPIC appealed to the National Labor Relations Commission (NLRC), which initially upheld the Labor Arbiter's decision but later reversed it, declaring DGMS as their employer.
  • Calimbas and Mahilom then appealed to the Court of Appeals (CA), which reversed the NLRC's decision and reinstated the Labor Arbiter's ruling.
  • FPIC subsequently filed a petition for review on certiorari with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. Yes, Calimbas and Mahilom were employees of FPIC.
  2. No, Calimbas and Mahilom were not lawful...(Unlock)

Ratio:

  • The Supreme Court upheld the Court of Appeals' finding that Calimbas and Mahilom were employees of FPIC and that DGMS was engaged in labor-only contracting.
  • DGMS did not have substantial capital or investment, and the workers were performing activities directly related to FPIC's business.
  • FPIC exercised control and supervision over Calimbas and Mahilom, further establishing the employer-employee relationship.
  • FPIC failed to sh...continue reading

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