Case Digest (G.R. No. 244629)
Facts:
In Marby Food Ventures Corporation et al. vs. Roland dela Cruz et al. (G.R. No. 244629, July 28, 2020), Marby Food Ventures Corporation (“Marby”) is a domestic corporation engaged in the production and distribution of baked goods. Mario Valderrama and Emelita Valderrama, President/CEO and Vice-President respectively, are the principal officers. Respondents Roland dela Cruz, Gabriel dela Cruz, Jose Paulo Anzures, Efren Tadeo, Bongbong Santos, Marlon de Rafael, Cris C. Santiago Jr., Elmer Maranao, Armando Rivera, Louie Balmes, and Raymond Pagtalunan were employed as drivers, while Mark Francis Bernardino was hired as a salesman. On September 30, 2016, respondents filed NLRC Case No. RAB-III-10-24653-16 against petitioners for underpayment of daily wage, overtime pay, holiday pay, 13th month pay, service incentive leave, sick and vacation leave under their CBA, illegal deductions and damages. Petitioners denied liability, contending drivers are field personnel not entitled to certaCase Digest (G.R. No. 244629)
Facts:
- Parties and Employment
- Marby Food Ventures Corporation (Marby) is a Philippine corporation manufacturing baked goods; Mario Valderrama is its President/CEO and Emelita Valderrama its Vice-President.
- Respondents (Roland dela Cruz, Gabriel dela Cruz, Jose Paulo Anzures, Efren Tadeo, Bongbong Santos, Marlon de Rafael, Cris C. Santiago, Elmer Marano, Armando Rivera, Louie Balmes, Raymond Pagtalunan) were employed as drivers; Mark Francis Bernardino was hired as salesman.
- Claims and Pleadings
- Respondents filed NLRC Case No. RAB-III-10-24653-16 alleging underpayment of daily wage, overtime pay, 13th month pay, non-payment of holiday pay, service incentive leave pay, vacation and sick leave pay, illegal deductions, moral and exemplary damages, and attorney’s fees.
- Bernardino separately alleged non-payment of 13th month, service incentive leave, vacation and sick leave pay, unauthorized deductions, and assignment of drivers’ and helpers’ salaries to him.
- Petitioners contended that respondents received minimum wage, 13th month pay, and lawful “penalty” deductions, and that field personnel are not entitled to overtime, holiday and service incentive leave benefits.
- Procedural History
- Labor Arbiter (December 15, 2016): Dismissed respondents’ claims with prejudice; held respondents were field personnel not entitled to contested benefits.
- NLRC (February 28, 2017; April 24, 2017): Partly reversed—ordered payment of wage differentials and 13th month pay to ten complainants and attorney’s fees of 10%; denied double indemnity and other benefits.
- Court of Appeals (October 19, 2018; January 21, 2019): Granted respondents’ petition for certiorari—ordered double salary differentials, overtime, holiday and service incentive leave pay, 13th month pay, reimbursement of deductions, 10% attorney’s fees, and 6% interest; dismissed petitioners’ petition.
- Supreme Court: Petitioners filed Rule 45 petition seeking to set aside the CA decision.
Issues:
- Are respondents “field personnel” or regular employees entitled to overtime, holiday and service incentive leave pay?
- Are respondents entitled to minimum wage salary differentials and 13th month pay differentials?
- Were the deductions made by petitioners from respondents’ wages unlawful?
- Are respondents entitled to attorney’s fees?
- Are petitioners liable to pay double indemnity under Section 12, RA 6727 as amended by RA 8188?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)