G.R. No. 126529 - Prangan vs. National Labor Relations Commission

Petitioner Eduardo B. Prangan was hired by the private respondent, Masagana Security Services Corporation, on November 4, 1980, as a security guard.
He was assigned to the Cat House Bar and Restaurant where he received a monthly salary of P2,000.00.
His employment continued until the establishment’s closure on August 31, 1993.

On May 4, 1994, petitioner filed a complaint against the private respondent for multiple unpaid benefits.
The claims included:

The private respondent denied full liability, contending that it merely acted as an agent in securing petitioner’s employment with the Cat House Bar and Restaurant, thereby shifting direct employer responsibility to the bar and its owner.

The Labor Arbiter resolved the dispute in a decision dated May 31, 1995.
The ruling ordered payment to petitioner by the respondents for a total sum of P9,932.16 covering selected wage claims.
Concomitantly, the Labor Arbiter dismissed other claims of the petitioner as well as the counterclaim of the respondents on grounds such as prescription or lack of merit.

Petitioner's appeal to the National Labor Relations Commission (NLRC) centered on the finding from the Labor Arbiter that he only worked four hours a day instead of twelve, which significantly reduced his computed benefits.
The NLRC initially dismissed the appeal due to a failure to file within the designated ten-day period.
Petitioner's subsequent motion for reconsideration was granted in the interest of justice, leading to the reinstatement of his appeal.
Ultimately, the NLRC dismissed the appeal for lack of merit, affirming the lower monetary award and the conclusion regarding the limited daily work hours.

The NLRC based its conclusion—that petitioner worked only four hours daily—primarily on daily time records submitted by the private respondent.
Petitioner contended that:

The daily time records were falsified.
He never completed or signed such records.
The authenticity of the records was questionable as he was never required to file them.

A personnel data sheet signed by the former operations manager indicating his work schedule as 7:00 p.m. to 7:00 a.m. (twelve hours).
Attendance sheets from the Cat House Bar and Restaurant confirming a twelve-hour work period.

The private respondent did not provide any additional employment documents such as employment contracts, payroll records, or cash vouchers to corroborate its claim.
The uniformity in the alleged time record entries (consistent daily start and end times) further contributed to raising serious doubts about their validity.

The appellate court evaluated the evidence and determined that the employer’s documentation could not be deemed substantial enough to confirm the four-hour workday claim.
The court underscored that when an employer alleges fewer work hours than provided under the law, it carries the burden to provide clear and satisfactory evidence.
With doubts arising between the conflicting evidence from the employer and the documented records submitted by the petitioner, the court applied the principle that in disputes between a laborer and his employer, doubts should be resolved in favor of the employee.
Consequently, the NLRC decision was vacated; the computation of benefits was to be recalculated based on a twelve-hour work schedule.
The case was remanded to the Labor Arbiter for immediate recomputation of the claims, with no costs imposed.

Whether the evidence presented by the private respondent—specifically the alleged daily time records—is sufficient to establish that the petitioner worked only four hours daily.

Determination of the authenticity and reliability of the submitted daily time records.
Assessment of conflicting documents, such as the personnel data sheet and attendance records, indicating a twelve-hour workday.

Whether the NLRC committed grave abuse of discretion in affirming the Labor Arbiter's conclusion on the number of hours worked by the petitioner.

Review of the NLRC’s evidentiary evaluation in light of the requirement for substantial evidence.
Consideration of whether doubts arising from the evidence should be resolved in favor of the employee.

Whether the recomputation of monetary awards based on the initial finding (four-hour workday) was justified given the material evidence suggesting a twelve-hour schedule.

Impact of the work-hour determination on the computed benefits such as overtime, premium pay, and other wage claims.
Adequacy of employer documentation versus the records provided by the petitioner.