G.R. No. 245266 - National Transmission Corp. vs. Religious of the Virgin Mary

Wilfredo Melchor was hired by Paguio Transport Corporation as a taxi driver on December 25, 1992.
He was engaged under the “boundary system” wherein he was assigned to drive a taxi unit on a 24‑hour schedule every two days.
Under this arrangement, Melchor remitted a fixed “boundary” fee of P650.00 per trip, and his net income consisted of whatever earnings exceeded that amount.
The petitioner contended that because the mode of payment was based on the boundary system, the typical employer control over work hours and routes was absent.

On November 24, 1993, Melchor was involved in a vehicular incident along Quirino Avenue near the PNR Station and Plaza Dilao when he allegedly bumped into another car that had halted at an intersection.
After submitting a traffic accident report, Melchor was advised by the company to rest, but upon reporting back to work several days later, he was informed that his services were no longer needed.
The dismissal gave rise to the complaint for illegal dismissal, with Melchor claiming that he was terminated without due process.

Melchor maintained that there existed an employer‑employee relationship based on the control exerted by the company through the boundary system.
The respondent (Paguio Transport Corporation) argued that no employer‑employee relationship existed, contending that the absence of control over working hours and routes rendered the relationship akin to a “wase-agreement” or lease of a chattel.
Additionally, the petitioner claimed that Melchor’s involvement in three vehicular accidents—on separate occasions, allegedly resulting in damages of varying amounts—justified his dismissal.
It was further argued that Melchor’s repeated accidents, including a serious incident on November 4, 1993, established a pattern of reckless driving.
However, petitioner failed to produce evidence other than bare allegations or documents submitted on appeal to substantiate the claims of reckless behavior or to prove that the accused accidents were sufficient to warrant termination.

The labor arbiter ordered reinstatement and awarded back wages based on a computation reflecting seven months of earnings.
The NLRC modified the award by recalculating the back wages to an amount of P86,400.00 and confirmed that Melchor was an illegally dismissed employee.
The NLRC further dismissed other claims for lack of evidence, noting that the mere allegation of negligence or recklessness did not meet the threshold for just cause.

Melchor sought reinstatement and full back wages pursuant to the provisions of the Labor Code.
The petitioner filed a petition for certiorari and prohibition assailing the NLRC’s decision and its subsequent resolution denying the motion for reconsideration.
The Supreme Court was called upon to review whether the NLRC acted with grave abuse of discretion or in excess of its jurisdiction, keeping in mind its limited judicial review function in fact-based determinations.

Whether the National Labor Relations Commission (NLRC) acted in excess of its jurisdiction and/or with grave abuse of discretion by ordering the reinstatement of Melchor along with full back wages, particularly in light of the alleged strained relations between the parties.
Whether the NLRC’s actions and the issuance of a preliminary injunction in favor of reinstatement were warranted given the interests of both the petitioner and the riding public.

Whether the petitioner, in dismissing Melchor, had established a just or authorized cause for termination.
Whether the dismissal met the twin requirements of due process, specifically the failure to provide Melchor with adequate notice and a proper hearing before his termination.
Whether the submission of documentary evidence on appeal (rather than at the labor tribunal level) precludes its consideration as sufficient to justify dismissal.

Whether the doctrine of strained relations, invoked by the petitioner to bar reinstatement, is applicable given the circumstances in which no concrete factual basis was provided for such strained relations.
Whether the alleged incidents of vehicular accidents, without corroborative evidence on recklessness or incompetence, are sufficient to establish strained employment relations that would preclude harmonious work conditions.