Case Digest (G.R. No. 179652) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People’s Broadcasting (Bombo Radyo Phils., Inc.) v. Secretary of the Department of Labor and Employment, DOLE Region VII and Jandeleon Juezan, respondent Jandeleon Juezan filed on September 18, 2003 before DOLE Regional Office No. VII, Cebu City, a complaint against petitioner Bombo Radyo for illegal deductions, non-payment of service incentive leave, 13th month pay, premium pay for holiday and rest day, illegal diminution of benefits, delayed payment of wages and non-coverage by SSS, Pag-IBIG and PhilHealth. A plant-level inspection on September 23, 2003 produced an Inspection Report noting “non-diminution of benefits” and management’s denial of an employer-employee relationship, supported by cash vouchers, billing statements, and written “employment for specific undertaking” contracts. Petitioner failed to rectify the cited violations within five days, prompting summary investigation. On February 27, 2004, Regional Director Rodolfo M. Sabulao issued an Order finding that Ju Case Digest (G.R. No. 179652) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Nature of the Controversy and Parties
- Petitioner People’s Broadcasting Service, Inc. (Bombo Radyo) was subjected to a labor inspection and subsequently ordered by DOLE to pay various money claims of respondent Jandeleon Juezan.
- Juezan filed before DOLE-RO VII complaints for illegal deductions, nonpayment of service incentive leave, 13th-month pay, premium pay for holiday and rest day, illegal diminution of benefits, delayed wages, and non-coverage of SSS, Pag-IBIG, and PhilHealth.
- DOLE Regional Proceedings
- On 23 September 2003, a DOLE labor inspector conducted a plant-level inspection. The Inspection Report noted “non-diminution of benefits” but recorded the employer’s denial of any employer-employee relationship.
- The Notice of Inspection Results (same date) reiterated management’s denial, citing per-drama contracts, cash vouchers, billing statements, and absence of payroll control.
- Petitioner failed to rectify the alleged violations within five days; DOLE conducted a summary investigation and required position papers from both parties.
- In an Order dated 27 February 2004, DOLE-RO VII Regional Director Rodolfo M. Sabulao ruled that Juezan was an employee of petitioner and granted money claims totaling ₱203,726.30.
- Petitioner’s motion for reconsideration was denied on 24 May 2004.
- Appeal to the DOLE Secretary and to the Court of Appeals
- Petitioner appealed to the DOLE Secretary but failed to post the required cash or surety bond, submitting instead a Deed of Assignment of Bank Deposit. The Acting Secretary dismissed the appeal on 27 January 2005.
- Petitioner filed a Rule 65 petition for certiorari with the Court of Appeals, claiming denial of due process and lack of jurisdiction by DOLE. On 26 October 2006 the CA denied relief; its 26 June 2007 resolution denied reconsideration.
- Supreme Court Petition
- Petitioner sought certiorari under Rule 65, arguing that DOLE lacked jurisdiction because no employer-employee relationship existed, that evidence was disregarded, and that its appeal bond had been wrongly rejected.
Issues:
- Whether DOLE had jurisdiction under Article 128(b) of the Labor Code, as amended by R.A. 7730, to decide money claims when employer-employee relationship was contested.
- Whether the DOLE Regional Director and the Secretary committed grave abuse of discretion or denied due process by disregarding petitioner’s documentary evidence.
- Whether the Deed of Assignment of Bank Deposit substantially complied with the cash or surety bond requirement to perfect an appeal under Article 128(b).
- Whether a Rule 65 petition for certiorari was the proper remedy instead of a Rule 45 petition for review on certiorari.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)