Case Digest (G.R. No. 221043) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case concerns a Petition for Review on Certiorari filed by Nozomi Fortune Services, Inc. (Nozomi), against Celestino A. Naredo (Naredo), arising from a complaint for illegal dismissal and regularization filed by Naredo and several others against Nozomi and its branch manager, Ludy Lasiog, as well as Samsung Electro-Mechanics Philippines (Samsung) and its officials. Nozomi, a manpower service provider registered with the Department of Labor and Employment (DOLE), hired complainants and assigned them as production operators at Samsung between 2003 and 2005. In May 2010, Samsung informed them that they would be absorbed as regular employees if they passed an examination, but they failed, and their services were no longer needed. Subsequently, on July 15, 2010, the complainants voluntarily resigned by submitting letters citing personal reasons. Nonetheless, a month later, they filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC), assertin Case Digest (G.R. No. 221043) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Complaint
- Petitioner Nozomi Fortune Services, Inc. (Nozomi) is a manpower service provider registered with the Department of Labor and Employment (DOLE).
- Respondent Celestino A. Naredo and several others (collectively, complainants) were hired by Nozomi and assigned to Samsung Electro-Mechanics Phils. (Samsung) as production operators between 2003 and 2005.
- Complainants filed a complaint for illegal dismissal and for regularization against Nozomi, its branch manager Ludy Lasiog, Samsung, its president Jung Soo Lee, and human resources manager Anna Roselle Dayday.
- Employment and Separation
- In May 2010, Samsung advised complainants that they could be absorbed as regular employees if they passed an examination; all complainants failed the test.
- On July 15, 2010, complainants tendered handwritten voluntary resignation letters citing personal reasons.
- About one month later, complainants filed a complaint for illegal dismissal and regularization before the National Labor Relations Commission (NLRC).
- Contentions of the Parties
- Complainants asserted they were regular employees of Samsung because:
- Their duties were necessary and desirable to Samsung’s usual business;
- Nozomi was merely a labor-only contractor without substantial capital or investment;
- The equipment they used belonged to Samsung;
- Samsung controlled and supervised their work;
- Nozomi acted only as a conduit for wage payments.
- Nozomi contended:
- It is duly registered with DOLE as an independent job contractor;
- It operates its own medical laboratory and diagnostic centers for employees;
- It owns training facilities and has service contracts with various companies, including Samsung;
- It has substantial capital and manages its own workforce.
- Samsung denied liability, maintaining complainants were Nozomi’s employees assigned under a service contract.
- Labor Arbiter Decision
- The Labor Arbiter dismissed the complaint for lack of merit.
- Found Nozomi a legitimate independent contractor, registered with DOLE and possessing substantial capital (net income of PHP 991 million in 2009).
- Noted the existence of various operational facilities owned by Nozomi, including medical, training, finance, and software centers.
- Found Nozomi exercised employer prerogatives over complainants (hiring, payment, discipline, termination, and control).
- Declared complainants voluntarily resigned; burden to prove dismissal rested on complainants but was not discharged.
- NLRC Rulings
- NLRC affirmed the Labor Arbiter’s Decision, concluding Nozomi was the legitimate employer applying the fourfold test.
- Found complainants failed to prove illegal dismissal or entitlement to monetary claims.
- Denied complainants’ motion for reconsideration.
- Court of Appeals Decision
- CA denied the Petition for Certiorari but reversed some NLRC findings.
- Declared Nozomi a labor-only contractor because:
- The service contract between Nozomi and Samsung was defective, only providing for manpower deployment without specific work or service;
- Nozomi failed to show substantial capital or investment beyond possessing capital alone;
- DOLE registration is not conclusive proof of legitimacy.
- Held Samsung as the true employer since Nozomi acted as Samsung’s agent.
- Upheld finding of voluntary resignation; found no illegal dismissal.
- Denied Nozomi’s Partial Motion for Reconsideration.
- Petition for Review on Certiorari and Supreme Court Action
- Nozomi filed the present petition challenging the CA’s rulings.
- The Supreme Court limited review to grave abuse of discretion by NLRC.
- The Court reexamined factual findings due to conflicting conclusions between labor tribunals and CA.
Issues:
- Whether the Court of Appeals erred in finding grave abuse of discretion amounting to lack or excess of jurisdiction on the part of the NLRC.
- Whether Nozomi Fortune Services, Inc. is a legitimate independent job contractor or a labor-only contractor.
- Whether respondent Celestino A. Naredo was illegally dismissed or voluntarily resigned.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)