Case Digest (G.R. No. 145271)
Facts:
Manila Electric Company v. Rogelio Benamira et al., G.R. No. 145271, July 14, 2005, Supreme Court Second Division, Austria‑Martinez, J., writing for the Court.The petition arose from claims by eight former security guards (hereafter the individual respondents) who originally worked for People’s Security, Inc. (PSI) and were deployed at MERALCO’s head office. PSI’s security service contract with MERALCO ended on November 30, 1990; on December 1, 1990 Armed Security & Detective Agency, Inc. (ASDAI) entered into a security service contract with MERALCO and absorbed many of PSI’s guards, including the individual respondents. Fifty‑six former PSI guards, including the eight respondents, filed NLRC‑NCR Case No. 05‑02746‑90 against PSI and MERALCO for unpaid monetary benefits; the Labor Arbiter decided in their favor on June 29, 1992.
Less than a month later the eight individual respondents filed another complaint (NLRC‑NCR Case No. 00‑07‑03953‑92) on July 21, 1992 against ASDAI and MERALCO for unpaid benefits; Advance Forces Security & Investigation Services, Inc. (AFSISI) supplanted ASDAI under a contract effective July 25, 1992. The respondents amended to implead AFSISI and later added illegal dismissal claims alleging, among other things, that AFSISI did not assign certain guards and had effectively terminated some without cause. ASDAI denied liability; MERALCO denied any employer‑employee relationship, pointing to the agency contracts designating the agencies as employers.
On January 3, 1994, Labor Arbiter Pablo C. Espiritu, Jr. found ASDAI the direct employer, dismissed the complaint against AFSISI, and ordered ASDAI and MERALCO to pay the monetary claims jointly and solidarily. The NLRC affirmed the Labor Arbiter’s decision on April 10, 1995 and denied reconsideration on May 23, 1995. The individual respondents later filed a certiorari petition before the Court (docketed G.R. No. 121232) which was, pursuant to St. Martin Funeral Homes, referred to the Court of Appeals (CA).
On September 27, 2000, the CA (CA‑G.R. SP No. 50520) modified the NLRC decision by declaring MERALCO the direct employer and ordered MERALCO to reinstate the respondents as regular MERALCO employees and to pay backwages and other benefits; the CA otherwise affirmed the Labor Arbiter’s findings, including joint and solidary liability for monetary claims. MERALCO filed this Rule 45 petition (G.R. No. 14527...(Subscriber-Only)
Issues:
- Did an employer‑employee relationship exist between MERALCO and the individual respondents?
- Were the individual respondents regular employees of MERALCO?
- Was it proper for the Court of Appeals to consider, for the first time in the CA memorandum, the respondents’ theory that MERALCO was their direct employer?
- Was MERALCO guilty of illegal dismissal of the individual respondents?
- Are the individual respondents entitled to reinstatement into MERALCO’s workforce?
- Is MERALCO entitled to reimbursement from ASD...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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