G.R. No. 122468 - Sentinel Security Agency, Inc. vs. National Labor Relations Commission

Two petitions for reconsideration were filed, one by Sentinel Security Agency, Inc. (the Agency) and one by Philippine American Life Insurance Company (the Client).
Both motions were filed following the Court’s September 3, 1998 decision in two distinct cases (GR Nos. 122468 and 122716) addressing issues of illegal dismissal and subsequent employee benefits.
The Agency’s motion reiterated the same basic issues and arguments previously resolved by the Court, while the Client sought a clarification regarding its liability in connection with the employees’ benefits.

The initial Decision clearly held that the illegal dismissal of the complainants was solely attributable to the Agency.
The decision noted that there was no justification—such as a suspension of operations or business—that could warrant placing the complainants on off-detail or causing a delay of six months.
As an immediate consequence of the illegal dismissal, the complainants were entitled to receive back wages, separation pay, and other benefits, but it was determined that responsibility for these was not uniformly shared by all parties.

The Court’s earlier decision absolved the Client from liability because it was not in a position to have committed the act of illegal dismissal.
This position was supported by citations from recent jurisprudence (such as Rosewood v. National Labor Relations Commission) emphasizing that punitive wage orders should not extend to an indirect employer without evidence of involvement in the dismissal.

Despite the Client’s exoneration from dismissal-related benefits, the Court reiterated that under Articles 106, 107, and 109 of the Labor Code the Client, as an indirect employer, is jointly and severally liable with the Agency.
This liability for service incentive leave accrues only to the extent of the work performed under the contract, confirming that the Client’s responsibility is limited to wages for work undertaken for its benefit.
The complainants’ service incentive leave pay was computed for the period covering 1991-1993, prior to the illegal dismissal on January 16, 1994.

The Agency’s Motion for Reconsideration was denied on the grounds that it merely reiterated previously decided issues without presenting new or substantial arguments.
The Client’s Motion was granted in part to clarify the record regarding its liability:

The Client is cleared from any liability for the payment of back wages and separation pay relating to the complainants.
However, the Client’s solidary liability with the Agency for the complaint service incentive leave pay was officially reiterated.

Whether the motion filed by the Agency, which repeated previously ruled issues regarding illegal dismissal and consequent employee benefits, should warrant reversal or modification of the earlier decision.
Whether the Client should be held liable for the complainants’ back wages and separation pay given that the illegal dismissal was solely attributable to the Agency.
Whether, despite the Client’s exoneration from dismissal-related benefits, the Client should still be held jointly and severally liable with the Agency for the service incentive leave pay pursuant to Articles 106, 107, and 109 of the Labor Code.