Case Digest (G.R. No. 187984) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Francisco A. Labao v. Lolito N. Flores, et al., G.R. No. 187984, decided on November 15, 2010, petitioner Francisco A. Labao, proprietor and general manager of the San Miguel Protective Security Agency (SMPSA), contracted security services for the National Power Corporation, Mindanao Regional Center (NPC-MRC) in Iligan City. Respondents Lolito N. Flores, Amado A. Daguisonan and seventeen fellow security guards, each earning a monthly salary of ₱7,020.00, were relieved of their NPC-MRC duties starting in September and October 2004 after they failed to comply with a July 27, 2004 memorandum demanding updated personal data files, professional licenses, and other documents by July 30, 2004. SMPSA ordered the respondents to report to its Senior Operations Officer for reassignment, but the guards remained off-detailed for more than six months. In March and April 2005, they filed with the Iligan City Sub-Regional Arbitration Branch of the NLRC individual complaints for illegal dismi Case Digest (G.R. No. 187984) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Francisco A. Labao is proprietor and general manager of San Miguel Protective Security Agency (SMPSA), a licensed security-service contractor.
- Respondents (20 security guards) were assigned to National Power Corporation, Mindanao Regional Center (NPC-MRC) in Iligan City, each earning ₱7,020.00 monthly.
- SMPSA’s Directive and Relief from Duty
- July 27, 2004: Petitioner issued memorandum requiring submission of updated personal data, professional license, and related documents by July 30, 2004 for contract renewal.
- Respondents failed to comply; petitioner relieved them from NPC-MRC duty in September–October 2004 and directed them to report for new assignments.
- Labor Complaints and Lower-Court Proceedings
- March–April 2005: Respondents filed consolidated complaints for illegal (constructive) dismissal and money claims before the Iligan City Sub-Regional Arbitration Branch of NLRC.
- SMPSA denied dismissal, citing valid management prerogative and proof of notice (January 17, 2005) to report for reassignment, which respondents allegedly ignored.
- Rulings Below
- Labor Arbiter (December 27, 2005): Dismissed complaints for lack of merit; relief from duty was legitimate management prerogative due to respondents’ non-submission of documents.
- NLRC (July 31, 2006; Sept. 29, 2006): Affirmed Labor Arbiter; off-detail did not exceed six-month permissible floating status; respondents failed to comply with January 2005 reassignment notice.
- Court of Appeals (Sept. 5, 2008; modified April 22, 2009): Found constructive dismissal (over six months off-detailed), awarded separation pay and backwages; dismissed late petition of one complainant but admitted others’ petition for certiorari.
- Petition for Review
- Petitioner sought reversal of CA decisions, arguing late filing of CA petition and correctness of LA and NLRC factual findings.
- Respondents contended timely filing based on their December 6, 2006 receipt of NLRC resolution and excusable negligence of former counsel.
Issues:
- Was the petition for certiorari before the Court of Appeals filed beyond the 60-day reglementary period, depriving that court of jurisdiction?
- Did the Court of Appeals err in reversing the factual findings of the Labor Arbiter and the NLRC and in declaring respondents constructively dismissed?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)