G.R. No. L-28896 - Commissioner of Internal Revenue vs. Algue, Inc.

Bienvenido Aricayos commenced work on February 6, 1995 as Operations Manager of St. Martin Funeral Home without a written contract or inclusion in the semi-monthly payroll.
On January 22, 1996, he was dismissed for alleged misappropriation of ₱38,000 intended for the funeral home’s VAT payment to the BIR.

St. Martin Funeral Home contended Aricayos was never an employee but merely a volunteer—and uncle of the owner, Amelita Malabed—who offered assistance out of gratitude after receiving financial help.
Following the death of Malabed’s mother in January 1996, Malabed took charge, discovered unpaid taxes despite ledger entries, and excluded Aricayos from management, prompting his illegal dismissal complaint.

Before NLRC Regional Arbitration Branch No. III, the Labor Arbiter (October 25, 1996) held there was no employer-employee relationship and dismissed for lack of jurisdiction.
On appeal, the NLRC (June 13, 1997) set aside the Arbiter’s decision and remanded for further proceedings; it denied reconsideration (August 18, 1997).
St. Martin Funeral Home filed a petition for certiorari before the Supreme Court, alleging grave abuse of discretion by the NLRC.

Whether an employer-employee relationship existed between St. Martin Funeral Home and Aricayos from February 1995 to January 1996.
Whether the Labor Arbiter and the NLRC had jurisdiction to resolve Aricayos’s illegal dismissal complaint.
What is the proper mode and forum for judicial review of NLRC decisions under the Labor Code and amended Judiciary Reorganization Act.