G.R. No. 98368 - Opulencia Ice Plant and Storage vs. National Labor Relations Commission

Manuel P. Esita had previously served for twenty (20) years as a compressor operator at Tiongson Ice Plant in San Pablo City.
In 1980, Esita was hired as a compressor operator-mechanic for the ice plants under petitioner Dr. Melchor Opulencia, located in Tanauan, Batangas, and Calamba, Laguna.
Esita’s initial assignment at the Tanauan ice plant earned him a daily wage of P35.00.

In 1986, Esita was transferred to the ice plant in Calamba, where he replaced an older compressor operator who had been relieved due to ill health.
During the overhauling of the Calamba plant, aside from his regular duties, Esita assisted in the repair and remodeling of the plant.
Esita also aided in the construction-remodeling of Dr. Opulencia’s house for less than a month.
Petitioners allowed Esita certain privileges:

Petitioners admitted that, as a token of gratitude and in keeping with the tradition of “pakikisama,” Esita would assist in cleaning the premises and engine room twice a month.

On February 6, 1989, Esita was dismissed from his post for demanding the correct wage amount due to him.
Following his dismissal, Esita filed a complaint with the Sub-Regional Arbitration Branch IV in San Pablo City for illegal dismissal, underpayment of wages, non-payment for overtime, legal holiday, premium for holiday and rest day benefits, 13th-month pay, separation/retirement pay, and other allowances.

On December 8, 1989, Labor Arbiter Numeriano D. Villena rendered a decision finding the existence of an employer-employee relationship between petitioners and Esita, awarding him separation pay and various wage and allowance benefits, but dismissing his claim for overtime pay due to lack of evidence.
On November 29, 1990, the Third Division of the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, albeit with a reduced monetary award due to issues regarding the proof that Esita worked continuously including rest days and prior to legal holidays.
A motion for reconsideration by petitioners was denied on March 26, 1991.

Petitioners contended that there was no employer-employee relationship between them and Esita, asserting that he was merely a helper or peon.
They argued that Esita’s work during the repair and construction phases did not amount to regular employment.
Petitioners maintained that the absence of Esita’s name in the company payrolls was proof of his non-employee status.
They asserted that the humanitarian privileges granted (free lodging, utilities, and cultivation rights) were benevolent acts and should not obligate them to comply with labor laws regarding employee benefits.
Petitioners also questioned the credibility of Esita’s testimony, particularly his claim of working continuously from 7 a.m. to 5 p.m.

The Labor Arbiter and NLRC found that testimonial evidence was sufficient to establish an employer-employee relationship, even in the absence of complete payroll records.
The court noted that under the Labor Code, an employee who has rendered at least one year of service is deemed regular, regardless of whether the service was continuous or interrupted.
Petitioners’ reliance on the absence of documentary evidence and selective payroll entries was rejected, as it was proven that not all employees were necessarily listed in the payroll due to customary practices.
The tribunal emphasized that the full spectrum of evidence—including witness testimonies and the employee’s long-term service—is valid and legally sufficient for determining employment status.

Petitioners sought reversal of the decisions of the Labor Arbiter and NLRC and a temporary restraining order to prevent enforcement of the awards.
The petition was ultimately dismissed, and the restraining order issued on May 13, 1991, was lifted, confirming Esita’s employee status and his entitlement to benefits.

Whether Esita’s engagement, despite being characterized by occasional tasks such as cleaning and helper functions, established a regular employment relationship.
Whether his involvement in both repair/remodeling operations and routine compressor operations was sufficient to classify him as a regular employee.

Whether testimonial evidence can outweigh the absence of documentary proof (e.g., time sheets, payroll records) in proving the employment relationship.
Whether incomplete payroll records (reflecting only selected periods) can be used to negate an employee’s status.

Whether the Labor Arbiter and NLRC have jurisdiction in cases where the employer-employee relationship is initially disputed.
Whether the granting of humanitarian benefits by petitioners exempts them from complying with statutory labor requirements.

Whether Esita’s claim of a continuous work schedule (7 a.m. to 5 p.m.) is credible in light of his additional responsibilities and the petitioners’ arguments regarding his ability to tend crops.