Case Digest (G.R. No. 151228) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rolando Y. Tan vs. Leovigildo Lagrama, G.R. No. 151228, decided on August 15, 2002 under the 1987 Constitution, petitioner Rolando Tan, president of Supreme Theater Corporation and general manager of Crown and Empire Theaters in Butuan City, engaged private respondent Leovigildo Lagrama as a painter to produce billboards and murals from September 1, 1988 until October 17, 1998. On that date, Tan accused Lagrama of urinating in his work area and ordered him to stop work and leave the premises. Lagrama denied the infraction, filed an illegal dismissal complaint before the Labor Arbiter, who on June 17, 1999 declared his dismissal illegal and awarded separation pay, backwages, 13th month pay, service incentive leave pay, and damages totaling ₱136,849.99. The NLRC Fifth Division reversed the award on June 30, 2000, ruling that Lagrama was an independent contractor. The Court of Appeals on May 31, 2001, granted Lagrama’s Rule 65 petition, annulled the NLRC resolutions, and reinsta Case Digest (G.R. No. 151228) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Employment
- Rolando Y. Tan is president of Supreme Theater Corporation and general manager of Crown and Empire Theaters in Butuan City.
- Leovigildo Lagrama worked as a painter of ad billboards and murals for the Empress, Supreme, and Crown Theaters from September 1, 1988 until October 17, 1998.
- Incident and Procedural History
- On October 17, 1998, Tan accused Lagrama of urinating in his work area, ordered him to stop drawing and to leave the premises. Lagrama denied the allegation.
- Lagrama filed for illegal dismissal before the NLRC, seeking separation pay, backwages, 13th-month pay, service incentive leave pay, salary differential, and damages.
- The Labor Arbiter (June 17, 1999) found the dismissal illegal and awarded P136,849.99.
- On appeal, the NLRC Fifth Division (June 30, 2000) reversed and held Lagrama to be an independent contractor; denied reconsideration (September 29, 2000).
- The Court of Appeals granted Lagrama’s petition (May 31, 2001), annulled the NLRC resolutions, and reinstated the Labor Arbiter; denied Tan’s motion for reconsideration (November 27, 2001).
- Tan filed a petition for review on certiorari before the Supreme Court raising five assignments of error, primarily contesting the existence of an employment relationship and the illegality of dismissal.
Issues:
- Whether an employer-employee relationship existed between Tan and Lagrama.
- Whether Lagrama was illegally dismissed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)