Case Digest (G.R. No. L-5208) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In JR Hauling Services and Oscar Mapue v. Gavino L. Solamo, et al. (G.R. No. 214294, September 30, 2020), petitioners JR Hauling Services, a domestic hauling corporation based in Bulacan, and its manager Oscar Mapue challenged the NLRC’s August 28, 2012 Decision that upheld the summary dismissal of respondents Gavino L. Solamo, Ramil Jerusalem, Armando Parungao, Rafael Caparos Jr., Noriel Solamo, Alfredo Salangsang, Mark Parungao, and Dean V. Calvo for alleged misconduct in transporting and delivering broiler chickens for clients such as Magnolia Corporation and San Miguel Foods, Inc. The drivers/helpers claimed on April 3, 2011 they were dismissed without due process and without valid cause. They filed before the Labor Arbiter (LA) complaints for illegal dismissal and non-payment of statutory benefits, seeking reinstatement, backwages, 13th month pay, holiday/rest-day pay, service incentive leave pay, and attorney’s fees. JR Hauling countered that respondents incurred shortages Case Digest (G.R. No. L-5208) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- JR Hauling Services (petitioner), a hauling and delivery company for live broiler chickens; Oscar Mapue, its manager.
- Respondents Gavino L. Solamo, Ramil Jerusalem, Armando Parungao, Rafael Caparos Jr., Noriel Solamo, Alfredo Salangsang, Mark Parungao, and Dean V. Calvo—drivers/helpers paid ₱300 per trip (₱600/day if two trips accomplished).
- Employment Terms and Alleged Violations
- Respondents transported broilers from farms (Pangasinan, Tarlac, Batangas, Bulacan, Zambales, La Union) to clients’ processing plant (Hermosa, Bataan). They secured replacement broilers for any chicken deaths in transit.
- Alleged shortages: 371 broilers (February 2011) and 377 broilers (March 2011) per an unsigned summary. Petitioners claimed respondents sold excess broilers and 232 broiler crates in Concepcion, Tarlac, without consent.
- Dismissal and Administrative Proceedings
- On April 3, 2011, respondents were barred from company premises and dismissed without written notice or hearing.
- Labor Arbiter (LA) ruled dismissal illegal, ordered reinstatement, backwages, salary differential, attorney’s fees; denied other benefits due to “field personnel” status.
- NLRC reversed LA: held loss of trust and confidence justified dismissal; denied reinstatement and salary differential.
- Court of Appeals (CA) granted certiorari: set aside NLRC decision, reinstated LA judgment.
Issues:
- Whether there was substantial evidence to support respondents’ dismissal for just cause.
- Whether respondents are entitled to salary differentials.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)