Case Digest (G.R. No. 236331)
Facts:
RNB Garments Philippines, Inc. v. Ramrol Multi-Purpose Cooperative, G.R. No. 236331; Ramrol Multi-Purpose Cooperative v. Myrna D. Desacada, G.R. No. 236332, September 14, 2020, Supreme Court Second Division, Delos Santos, J., writing for the Court.RNB Garments Philippines, Inc. (RNB) is a garment manufacturer/exporter that engaged Ramrol Multi-Purpose Cooperative (RMPC) to perform garment-manufacturing services; RMPC in turn supplied the services of the employees hereinafter referred to collectively as Desacada, et al. The workers performed tasks as sewers, trimmers, revisers, quality-control staff, and sewing mechanic. On October 10, 2011 RNB stopped loading RMPC’s sewing line, allegedly because of minimal loading from its principal vendor, which resulted in the workers’ suspension or lay-off for more than six months and, in some instances, a verbal dismissal claimed to have occurred on October 19, 2011.
The dismissed/suspended workers filed individual complaints for illegal dismissal against RNB and RMPC before the Labor Arbiter (LA). The LA (Decision dated November 29, 2012) found that RMPC was a mere agent/labor-only contractor and that RNB was the true employer; it declared the respondents guilty of illegal dismissal and ordered immediate reinstatement and monetary awards. RNB alone appealed to the National Labor Relations Commission (NLRC). The NLRC initially dismissed the appeal as procedurally infirm, but upon reinstatement (Resolution April 30, 2014) affirmed the LA’s findings that RNB was the real employer and that the workers had been illegally dismissed; because RNB had ceased operations by December 31, 2012, the NLRC modified the LA’s reinstatement order into backwages and separation pay up to the cessation date and affirmed other awards.
Both RNB and RMPC filed petitions for certiorari with the Court of Appeals (CA). The CA (Decision May 26, 2017; Resolution December 28, 2017) dismissed both petitions, affirming the LA and NLRC findings that RMPC was a labor-only contractor, that RNB was the true employer, and that the workers had been...(Pro-only)
Issues:
- Procedural: Whether the Labor Arbiter’s Decision dated 29 November 2012 had become final and executory as to RMPC despite RMPC’s failure to appeal.
- Substantive: Whether RMPC is a labor-only contractor under Article 106 of the Labor Code.
- Substantive: Whether an employer-employee relationship exists between RNB and Desacada, et al..
- Substantive: Whether Desacada, et al. were i...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)