Case Digest (G.R. No. 252189) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 120969 decided on January 22, 1998 under the 1987 Philippine Constitution, petitioners Alejandro Maraguinot, Jr. and Paulino Enero were engaged by private respondents Vic del Rosario and Viva Films beginning July 18, 1989 (Maraguinot) and June 1990 (Enero) as part of a shooting crew with weekly salaries rising from ₱375.00 to as much as ₱593.00. Their tasks—loading, unloading and arranging equipment, assisting in lighting, returning gear to Viva’s warehouse and performing duties as directed by the cameraman or director—were essential to the movie-making business. In May 1992 they refused to sign blank employment contracts and were thereafter either forced on leave or dropped from the payroll; by July 20, 1992 both were effectively separated when their respective film projects were completed. They filed illegal dismissal complaints before the Labor Arbiter, who on December 20, 1993 declared their dismissal unlawful, ordered their reinstatement with back wages of ₱38,0 Case Digest (G.R. No. 252189) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment Background
- Alejandro Maraguinot, Jr.
- Hired 18 July 1989 as part of filming crew
- Weekly salary: ₱375 → Assistant Electrician ₱400 (Nov 1989) → ₱450 (May 1990) → Electrician ₱475 (June 1991) → ₱593 (Sept 1991)
- Paulino Enero
- Hired June 1990 as shooting crew member
- Weekly salary: ₱375 → ₱425 (May 1991) → ₱475 (Dec 1991)
- Work Assignments and Termination Events
- Duties: loading/unloading and arranging equipment, returning gear to Viva warehouse, assisting in lighting setup, other crew tasks
- May–July 1992 dispute over wage adjustment
- Petitioners refused to sign blank employment contracts
- Enero placed on leave June 1992 and not reinstated (reported 20 July 1992)
- Maraguinot dropped from payroll 8–21 June 1992, reinstated 22 June, then terminated 20 July 1992
- Procedural History
- Labor Arbiter (20 Dec 1993) found illegal dismissal; ordered reinstatement and backwages (Maraguinot ₱46,000; Enero ₱38,000) + attorney’s fees
- NLRC Decision (10 Feb 1995) reversed, classifying petitioners as “project employees”; Motion for Reconsideration denied (6 Apr 1995)
- Petitioners filed Special Civil Action for Certiorari (Rule 65) before the Supreme Court
Issues:
- Whether an employer-employee relationship existed between petitioners and respondents.
- Whether petitioners were project employees or regular employees.
- Whether petitioners’ dismissal upon project completion was illegal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)