Case Digest (G.R. No. 220617) Core Legal Reasoning Model
Facts:
In 1995, Angelina Francisco was engaged by Kasei Corporation in Makati as Accountant and Corporate Secretary liaison to secure permits and licenses, although she never handled corporate documents or attended board meetings and only signed papers occasionally. In 1996, she was further appointed Acting Manager with responsibilities for recruitment, administration, government liaison (BIR, SSS, Makati City), and overall restaurant operations, receiving ₱27,500 monthly, a ₱3,000 housing allowance, and a 10% share in profits. In January 2001, she was replaced as manager, informed she would continue as Technical Assistant, but her salary was reduced by ₱2,500 monthly from January to September, withheld in October, and she was later told she was no longer connected with the company. She then stopped reporting for work and filed for constructive dismissal with the Labor Arbiter. Respondents countered that she was a technical consultant, not an employee, worked at her own discretion, wa
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Case Digest (G.R. No. 220617) Expanded Legal Reasoning Model
Facts:
- Engagement and duties
- In 1995, petitioner Angelina Francisco was hired by Kasei Corporation during its incorporation stage as Accountant and Corporate Secretary, and designated Liaison Officer to the City of Makati to secure permits and licenses.
- Although titled Corporate Secretary, she never attended board meetings, prepared legal documents, or maintained corporate records, except on occasion when asked to sign pre-prepared documents.
- Promotion to Acting Manager and related assignments
- In 1996, petitioner was appointed Acting Manager; the corporation hired a separate accountant to assume her former accounting duties.
- As Acting Manager, she handled recruitment, management administration, dealings with government agencies (BIR, SSS, Makati city government), and operational matters of Kasei Restaurant.
- Compensation and benefits
- From 1996 to December 31, 2000, petitioner received a monthly salary starting at an unspecified amount, rising to ₱27,500 plus ₱3,000 housing allowance, and a 10% share in corporate profits.
- She received mid-year bonuses, 13th-month pay, and benefits, as evidenced by check vouchers and SSS contributions.
- Replacement, pay reduction, and non-payment
- In January 2001, Liza R. Fuentes replaced petitioner as Manager; petitioner was told she would serve as Technical Assistant to Seiji Kamura in charge of BIR matters.
- January–September 2001: Salary reduced by ₱2,500 monthly (total ₱22,500); mid-year bonus withheld; October 2001: salary unpaid and petitioner informed she was no longer connected with the company.
- Petitioner ceased reporting for work and filed for constructive dismissal.
- Procedural history
- Labor Arbiter (July 31, 2002) found employer-employee relationship, ruled dismissal illegal, ordered reinstatement or separation pay plus backwages, bonuses, allowances, profit share, damages and attorney’s fees.
- NLRC (April 15, 2003) affirmed with modifications: granted separation pay in lieu of reinstatement, full backwages to July 31, 2002, deleted moral/exemplary damages and profit share, adjusted attorney’s fees basis.
- Court of Appeals (October 29, 2004) reversed and dismissed the complaint; motion for reconsideration denied (October 7, 2005).
- Petitioner elevated the case to the Supreme Court by Rule 45 petition.
Issues:
- Whether an employer-employee relationship existed between petitioner and Kasei Corporation.
- Whether the actions of Kasei Corporation amounted to illegal or constructive dismissal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)