Case Digest (G.R. No. 182255)
Facts:
Petron Corporation v. Armz Caberte et al., G.R. No. 182255, June 15, 2015, the Supreme Court Second Division, Del Castillo, J., writing for the Court.
Petitioner Petron Corporation owns and operates petroleum bulk plants, including the Bacolod Bulk Plant, where the ten respondents (workers) were employed from various dates between 1979 and 1998 in functions such as LPG/Gasul filling, maintenance, warehouse and tanker receiving duties. From March 1, 1996 to February 28, 1999 and November 1, 1996 to June 30, 1999 Petron contracted with ABC Contracting Services (ABC) — owned by Antonio B. Caberte, Sr. — under a Contract for Services and a Contract for LPG Assistance Services to supply utility and maintenance manpower.
On July 2, 1999 respondents (grouped in three consolidated complaints) filed before the Labor Arbiter claims for illegal dismissal and various monetary claims against Petron, ABC and Caberte Sr. after being denied entry to work on July 1, 1999. They alleged ABC was a labor‑only contractor and that Petron was their true employer; Petron contended ABC was an independent contractor and that respondents were ABC’s employees.
The Executive Labor Arbiter (Labor Arbiter Danilo C. Acosta) dismissed claims against Petron, found ABC to be an independent contractor, treated respondents as ABC employees, and awarded separation pay for ABC’s cessation of operations (March 7, 2002 Decision). The NLRC affirmed the Labor Arbiter in its May 14, 2003 Decision and denied reconsideration in a November 27, 2003 Resolution.
Respondents petitioned the Court of Appeals for certiorari, alleging grave abuse of discretion by the NLRC; the CA reversed in a November 14, 2007 Decision, declaring ABC a labor‑only contractor, finding respondents to be Petron’s regular employees, and ordering reinstatement (or separation pay) with backwages and attorney’s fees; a March 4, 2008 CA Resolution denied Petron’s motion for re...(Pro-only)
Issues:
- Did the Court of Appeals err in finding that ABC Contracting Services was a labor‑only contractor rather than an independent contractor?
- Were the respondents thereby regular employees of Petron Corporation?
- Were respondents’ terminations illegal entitling them to reinstatement or separation pay and backwages?
- Should Antonio Caberte, Jr.’s complaint against Pe...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)