Case Digest (G.R. No. L-24866)
Facts:
Oscar S. Ortiz v. Forever Richsons Trading Corporation, Charverson Wood Industry Corporation, and Adan Co, G.R. No. 238289, January 20, 2021, Supreme Court Second Division, Lopez, J., writing for the Court. Petitioner Oscar S. Ortiz filed on June 28, 2013 a complaint for illegal dismissal and money claims against respondents Forever Richsons Trading Corporation (now Charverson Wood Industry Corporation) and Adan Co. Oscar alleged he was hired in June 2011, worked beyond an initial five-month contract, performed tasks integral to respondents’ plywood manufacturing business, refused to sign a new five‑month contract and other documents in April 2013, and was thereafter dismissed without just cause; he sought reinstatement, backwages and other monetary benefits.Respondents maintained Oscar was an employee of Workpool Manpower Services (Workpool Manpower), a DOLE‑registered job contractor, and that Oscar’s employment terminated by reason of the expiration of his contract with Workpool Manpower; they produced registration certificates and alleged Workpool paid wages and statutory contributions. Oscar denied that he was Workpool’s employee and alleged respondents submitted forged documents.
The Labor Arbiter (LA), in a Decision dated November 28, 2013, dismissed Oscar’s complaint for failure to implead Workpool Manpower as an indispensable party but nonetheless found Oscar to be a regular employee of Workpool Manpower and held that Workpool was a legitimate labor contractor. Oscar appealed to the National Labor Relations Commission (NLRC), which on June 11, 2014 denied the appeal and affirmed the LA’s ruling that Workpool was an indispensable party; the NLRC likewise denied reconsideration.
Oscar filed a petition for certiorari with the Court of Appeals (CA), which on September 22, 2017 dismissed the petition and affirmed the NLRC decision focusing on Oscar’s refusal to obey the LA’s order to implead Workpool Manpower; a February 21, 2018 CA resolution denied reconsideration. Oscar then filed a petition for revi...(Pro-only)
Issues:
- May the Supreme Court review and re-evaluate findings of fact affirmed or upheld by quasi‑judicial bodies in this case?
- Was Workpool Manpower Services a labor‑only contractor such that its personality is merged with the respondents and Oscar is an employee of the respondents?
- Was petitioner Oscar S. Ortiz illegally dismissed, and w...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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