Case Digest (G.R. No. 144672)
Facts:
San Miguel Corporation v. Maerc Integrated Services, Inc., G.R. No. 144672, July 10, 2003, Supreme Court Second Division, Bellosillo, J., writing for the Court.Two hundred ninety-one (291) workers filed nine consolidated complaints against San Miguel Corporation (SMC) and Maerc Integrated Services, Inc. (MAERC) for illegal dismissal, underpayment of wages, nonpayment of service incentive leave pays and other labor standards benefits, and for separation pay for the period 25 June to 24 October 1991. The complainants alleged they were recruited by MAERC to perform bottle-washing and segregation work at two Mandaue City sites (an SMC premises at Mandaue Container Services and the MAERC-owned Philphos warehouse) and that many had worked for SMC (under prior contractors) continuously before MAERC’s incorporation.
SMC denied employer status and maintained MAERC was an independent contractor. SMC and MAERC had a written Contract of Services beginning 1 February 1988, renewed in March 1989 and renewable month-to-month thereafter; on 15 May 1991 SMC notified MAERC that the contract would terminate end of June 1991 as SMC planned to phase out segregation work. When MAERC’s services ceased, the complainants were prevented from working and alleged illegal dismissal by SMC, asserting MAERC was only a sham intermediary.
The Labor Arbiter (Decision of 31 January 1995) found MAERC to be an independent contractor, dismissed the illegal dismissal claims against SMC, ordered MAERC to pay separation benefits totaling P2,334,150.00, and ordered MAERC and SMC jointly and severally to pay wage differentials of P845,117.00 and attorney’s fees of P317,926.70. The complainants appealed the Labor Arbiter’s characterization of MAERC as an independent contractor; SMC appealed the attorney’s fees award.
The National Labor Relations Commission (NLRC) (Decision of 7 January 1997) reversed the Labor Arbiter and held MAERC to be a labor-only contractor, declaring the complainants employees of SMC and making SMC solidarily liable with MAERC for MAERC’s unpaid obligations; NLRC awarded separation pay, wage differentials and a P2,000 indemnity to each worker. On reconsideration the NLRC reduced attorney’s fees to P84,511.70 but otherwise left its decision intact.
SMC filed a petition for certiorari (with prayer for injunctive relief) that was referred to the Court of Appeals, which on 28 April 2000 denied the petition and affirmed the NLRC. The Court of Appeals denied reconsideration in a resolution dated 26 July 2000. SMC then sought review before the Supreme Court via a Rule 45 petition (G.R. No. 144672).
The Supreme Court reviewed the factual record and the NLRC/CA findings of control and dependence, and identified evidentiary indicia (SMC’s role in recruitment, presence of SMC checkers and supervisory reports naming specific workers for discipline, SMC’s payment of employe...(Pro-only)
Issues:
- Are the complainants employees of San Miguel Corporation or of Maerc Integrated Services, Inc.?
- Was MAERC a labor-only contractor (as opposed to a legitimate job contractor), thereby making SMC solidarily liable for the workers’ claims?
- Should the monetary awards (separation pay, wage differentials, attorney’s fees, indemnity) be modified/recomputed because of duplicated or ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)