Title
Reyes vs. Glaucoma Research Foundation, Inc.
Case
G.R. No. 189255
Decision Date
Jun 17, 2015
A consultant claimed illegal dismissal, alleging an employer-employee relationship; the Supreme Court ruled none existed, citing lack of control and economic dependence.

Case Digest (G.R. No. 189255)
Expanded Legal Reasoning Model

Facts:

  • Petitioner’s Allegations
    • On August 1, 2003, petitioner was hired by Glaucoma Research Foundation, Inc. as Administrator of its Eye Referral Center (ERC) with a monthly salary of ₱20,000.00.
    • From February 2005, respondents withheld his salary and 14th-month pay without notice. Despite this, he continued reporting to work.
    • On April 11, 2005, petitioner wrote to Executive Director Manuel Agulto informing him of unpaid salaries; no response was received.
    • On April 21, 2005, petitioner was informed he was no longer ERC Administrator, and his office was padlocked. On April 29, 2005, he was barred entry to the premises.
  • Respondents’ Contentions
    • Petitioner was engaged as a consultant/adviser in corporate organizational structure and later self-designated as ERC Administrator on a trial basis.
    • No employer-employee relationship existed: petitioner set his own hours, was unsupervised in method, and received consultancy allowances. Respondents allege voluntary severance, not dismissal.
  • Procedural History
    • Labor Arbiter (LA) Decision (Jan. 20, 2006): dismissed petitioner’s complaint for failure to prove employer-employee relationship.
    • NLRC Decision and Resolution (May 2008): reversed LA, found illegal dismissal, ordered reinstatement with full backwages; motion for reconsideration denied.
    • Court of Appeals (CA) Decision (Apr. 20, 2009) and Resolution (Aug. 25, 2009): annulled NLRC, reinstated LA; denied petitioner’s motion for reconsideration.
    • Petition for Review on Certiorari filed with the Supreme Court, raising two principal grounds.

Issues:

  • Whether the CA erred in not dismissing respondents’ petition for certiorari due to improper verification under the 2004 Rules on Notarial Practice.
  • Whether the CA erred in ruling that no employer-employee relationship existed between petitioner and respondents.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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