Title
People's Broadcasting vs. Secretary of the Department of Labor and Employment
Case
G.R. No. 179652
Decision Date
May 8, 2009
DOLE upheld jurisdiction over labor claims, affirming employer-employee relationship between Bombo Radyo and Juezan, enforcing labor standards without due process denial.

Case Digest (G.R. No. 179652)
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)

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