Case Digest (G.R. No. 119268)
Facts:
Angel Jardin, Demetrio Calagos, Urbano Marcos, Rosendo Marcos, Luis de los Angeles, Joel Ordeniza and Amado Centeno v. National Labor Relations Commission (NLRC) and Goodman Taxi (Philjama International, Inc.), G.R. No. 119268, February 23, 2000, Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioners were taxi drivers employed by private respondent Philjama International, Inc. (Goodman Taxi) under a boundary system in which drivers took out taxi units and paid a daily "boundary" fee to the owner-operator and retained the excess earnings; petitioners averaged P400.00 daily. Private respondent regularly deducted P30.00 daily from drivers' takings allegedly for washing the units. Believing the deduction illegal and to protect their rights, petitioners organized a union. When petitioners reported for work on August 6, 1991 and subsequent days, they were refused assignment of taxis; petitioners suspected they were singled out for union activity.
Petitioners filed with the labor arbiter a complaint for unfair labor practice, illegal dismissal and illegal deduction of washing fees. On August 31, 1992, the labor arbiter dismissed the complaint for lack of merit. On appeal the NLRC reversed in a decision dated April 28, 1994, declaring petitioners employees, finding the dismissals illegal, directing reinstatement with full backwages and reimbursement of washing charges, and dismissing the unfair labor practice charge for insufficiency of evidence. Private respondent's first motion for reconsideration was denied. Private respondent filed a second motion for reconsideration; in a decision dated October 28, 1994, the NLRC granted that second motion, set aside its April 28, 1994 decision, held that no employer-employee relationship existed (characterizing the relationship as leasehold/charter), and dismissed the complaint for lack of jurisdiction. A subsequent motion for reconsideration by petitioners was denied by the NLRC.
Petitioners filed a special civil action for certiorari before the Court seeking annulment of the NLRC's October 28, 1994 decision and its December 13, 1994 resolution denying reconsideration. They alleged (1) the NLRC had no jurisdiction to entertain the second motion for reconsideration because Rule 7, Section 14 of its rules allows only one motion for reconsidera...(Subscriber-Only)
Issues:
- Did the NLRC gravely abuse its discretion by entertaining and granting private respondent's second motion for reconsideration in violation of its Rules (Rule 7, Sec. 14)?
- Did res judicata or finality principles bar the NLRC from reversing its earlier April 28, 1994 decision?
- Were petitioners taxi drivers employees of private respondent under the boundary system such that their dismissal was illegal and what remedies, if any, should they receive (inc...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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