Title
Martinez vs. Magnolia Poultry Processing Plant
Case
G.R. No. 231579
Decision Date
Jun 16, 2021
Daily-paid workers assigned to SMFI-MPPP via Romac claimed illegal dismissal; SC ruled Romac as a legitimate contractor, no employer-employee relationship with SMFI-MPPP.

Case Digest (G.R. No. 231579)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
  • Petitioners Ronald O. Martinez and twenty-seven others (employees) filed a complaint for illegal dismissal with monetary claims against respondent San Miguel Foods, Inc. (SMFI-MPPP) and Romac Services and Trading Co., Inc. (Romac), their contractor.
  • Martinez, et al. were hired by Romac as daily paid rank and file employees assigned primarily to the production department of SMFI-MPPP engaged in poultry processing. Their tasks included sanitation work but notably also tasks directly connected to poultry processing such as receiving, dressing, packaging, deboning, and inspection.
  • SMFI-MPPP contended that Romac was a legitimate labor contractor supplying only peripheral services such as janitorial and housekeeping and that the employees were Romac’s employees rather than theirs.
  • Romac described itself as a legitimate contracting company with substantial capital and business distinct from SMFI-MPPP. It maintained that it hired, paid, disciplined, and exercised control over its employees, including Martinez, et al.
  • Martinez, et al. ceased working in January 2010 when SMFI-MPPP ceased operations in preparation for outsourcing services. They claimed illegal dismissal and asserted entitlement to regular employee benefits and CBA (Collective Bargaining Agreement) benefits from SMFI-MPPP.
  • Procedural History
  • The Labor Arbiter ruled in favor of Martinez, et al., declaring Romac a labor-only contractor and SMFI-MPPP as the true employer, thus ordering reinstatement and payment of backwages.
  • The National Labor Relations Commission (NLRC) reversed the Labor Arbiter, ruling Romac a legitimate labor contractor and denying illegal dismissal claims against SMFI-MPPP.
  • The Court of Appeals (CA) reinstated the Labor Arbiter’s ruling, affirming Romac as labor-only contractor and SMFI-MPPP as the true employer, and ordering payment of monetary claims.
  • Both Martinez, et al. and SMFI-MPPP filed separate petitions for review on certiorari before the Supreme Court seeking relief.

Issues:

  • Whether Romac Services and Trading Co., Inc. is a legitimate labor contractor or a labor-only contractor.
  • Whether Martinez, et al. are regular employees of SMFI-MPPP entitled to regular employee benefits and entitled to reinstatement for illegal dismissal.
  • Whether the Court should defer or review the factual findings of the lower labor tribunals and the Court of Appeals on the issue of labor-only contracting.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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