Case Digest (G.R. No. 204052-53) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In San Miguel Foods, Inc. v. Rivera et al., G.R. No. 220103, decided January 31, 2018 under the 1987 Constitution, the petitioner San Miguel Foods, Inc. (SMFI), a poultry and feed business, engaged IMSHR Corporate Support, Inc. (ICSI) as an independent contractor to provide invoicing services from January 17, 2005 to July 16, 2005, renewable on a month-to-month basis. ICSI assigned its employees, including the respondents Hannival V. Rivera, Jovicell B. Fuja, and thirty-one others, to perform tasks such as witnessing unloading, preparing delivery receipts, and submitting liquidation reports. In 2009 SMFI decided to relocate its invoicing operation from its head office to its San Fernando, Pampanga plant; it advised ICSI, which informed the responses to submit transfer requests by July 13, 2009. Most respondents did not transfer and either tendered their resignations or ceased reporting. Thereupon, they filed consolidated complaints with the Labor Arbiter for constructive dismiss Case Digest (G.R. No. 204052-53) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Dispute
- Petitioner: San Miguel Foods, Inc. (SMFI), a corporation engaged in feeds, poultry and meats business.
- Respondents: Invoicing personnel assigned to SMFI through IMSHR Corporate Support, Inc. (ICSI), who filed complaints after SMFI discontinued invoicing operations at its head office.
- Contractual Arrangement and Employment Relationship
- In January 2005, SMFI contracted ICSI for six months to perform invoicing services, with a month-to-month renewal clause thereafter.
- ICSI assigned its employees (the respondents) to SMFI; tasks included witnessing unloading of poultry products, preparing invoices and delivery receipts, securing receiving documents, and submitting daily reports.
- In mid-2009, SMFI opted to relocate its invoicing operations to San Fernando, Pampanga; only one respondent accepted transfer, others resigned, continued working, or ceased reporting.
- Respondents filed consolidated complaints for constructive dismissal, regularization, unpaid benefits, and damages before the Labor Arbiter (LA).
- Procedural History
- The LA (Feb. 17, 2010) dismissed the complaints, finding ICSI a legitimate contractor and the respondents’ employer under the four-fold test.
- The National Labor Relations Commission (NLRC) (Sept. 28, 2010) affirmed the LA Decision and denied reconsideration.
- The Court of Appeals (CA) (Oct. 28, 2014) reversed: held SMFI was the respondents’ true employer, ordered reinstatement and backwages; denied reconsideration (Aug. 18, 2015).
- SMFI filed this petition for review on certiorari under Rule 45.
Issues:
- Legitimacy of Contractor
- Whether ICSI is a legitimate job contractor or a prohibited labor-only contractor under Article 106 of the Labor Code and DOLE implementing rules.
- Employer-Employee Relationship
- Whether an employer-employee relationship exists between SMFI and the respondents, entitling them to regularization, reinstatement, and benefits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)