Case Digest (G.R. No. 204684) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Allan Regala v. Manila Hotel Corporation, petitioner Allan Regala was engaged by respondent Manila Hotel Corporation (MHC) as a waiter in February 2000 and later assigned to other food and beverage outlets, earning ₱382.00 per day for six days weekly. MHC remitted SSS and PhilHealth contributions on his behalf. Over nearly a decade, Regala performed core duties—preparing mise en place, taking orders, and serving guests—and attended hotel trainings on food safety and customer service. On December 2, 2009, MHC allegedly reduced his work schedule from five to two days per week, diminishing his salary. Regala filed before the Labor Arbiter a complaint for constructive dismissal, regularization, non‐payment of paternity leave, and backwages. The Arbiter dismissed the complaint, classifying him as a fixed-term “extra waiter.” The NLRC reversed, applying the presumption of regular employment under Article 295 of the Labor Code and finding that his duties were necessary and desirable Case Digest (G.R. No. 204684) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment
- Allan Regala was hired by Manila Hotel Corporation (MHC) in February 2000 as a waiter and later cook helper, working six days a week at a daily rate of ₱382.00, with SSS and PhilHealth contributions.
- His duties included preparing the mise en place, taking orders, and serving guests at various outlets (Cowrie Grill, Pool Bar, Room Service, Banquet Services, etc.). He reported to a Captain Waiter and attended trainings on basic food safety, food safety awareness, and customer service awareness.
- Contractual engagement
- MHC treated Regala as an “extra waiter,” engaging him under fixed-term Service Agreements during spikes in business. Sample agreements covered only specific dates (e.g., March 1–3, 2010), stated no employee status, and terminated upon function completion.
- No written contract from his initial February 2000 hiring was produced. The Service Agreements’ duration and expiration terms were vague, unilaterally drafted by MHC’s Personnel Department, and did not allow negotiation.
- Procedural history before the Supreme Court
- Labor Arbiter Decision (Sept. 8, 2010): Dismissed Regala’s complaint—found him a fixed-term employee, no coercion in signing agreements, no constructive dismissal, denied backwages and other claims.
- NLRC Decision (Mar. 24, 2011) and Resolution (May 31, 2011): Reversed Arbiter—held Regala a regular employee (presumption of regularity; duties necessary to MHC’s business), found constructive dismissal by reducing workdays from five to two (starting Dec. 2, 2009), ordered reinstatement with backwages.
- Court of Appeals Decision (May 22, 2012) and Resolution (Nov. 19, 2012): Set aside NLRC—held valid fixed-term agreements, no illegal or constructive dismissal, dismissed complaint.
- Supreme Court proceedings: MHC’s motion to admit belated DTRs and payroll journals (Mar. 2009–Feb. 2016) and new theory of no dismissal was denied; main issues were filed under Rule 45.
Issues:
- Whether Allan Regala is a regular employee of Manila Hotel Corporation.
- Whether Regala was constructively dismissed from employment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)