Case Digest (G.R. No. 201022) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Technical Education and Skills Development Authority (TESDA) v. Ernesto Abragar, Abragar filed on April 29, 2003, a labor complaint before the Regional Arbitration Branch of the NLRC in San Fernando City, Pampanga, against the so-called Marble Center and his supervisor, Philip Bronio, for underpayment and non-payment of wages, service incentive leave, and 13th month pay. Abragar later amended his complaint to include constructive dismissal, separation and retirement pay, and damages. During the mandatory conference, Bronio appeared for the Center but failed to file a position paper, leading the Labor Arbiter (LA) on July 30, 2004, to find constructive dismissal and order the Center and Bronio to pay separation pay, backwages, salary differential, service incentive leave pay, and 13th month pay. No timely appeal was filed. Execution was frustrated when entry to levy assets on the TESDA compound was denied. Bronio’s motion for relief from judgment was dismissed by the NLRC on J Case Digest (G.R. No. 201022) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Factual Background
- On April 29, 2003, Ernesto Abragar filed a complaint before the NLRC Regional Arbitration Branch in San Fernando City against Marble Center (a training facility at TESDA, Guiguinto, Bulacan) and his supervisor, Philip Bronio, for underpayment/non-payment of wages, service incentive leave, 13th-month pay, and later constructive dismissal, separation pay, retirement pay, damages, and attorney’s fees.
- Abragar alleged he was hired in September 1997 as a marble operator, worked six days a week until December 2002 when his schedule and pay were abruptly reduced, constituting constructive dismissal.
- Procedural History
- Labor Arbiter Decision (July 30, 2004): The LA found constructive dismissal, awarded separation pay (₱28,630.00), backwages (₱109,174.00), salary differential (₱17,492.67), service incentive leave pay (₱3,007.50), and 13th-month pay (₱5,746.00). No appeal was filed.
- NLRC Resolutions and Execution:
- December 29, 2004: Bronio’s motion for reconsideration; January 25, 2005: petition for relief from judgment—both denied, Decision became final.
- Writ of execution issued; sheriff’s levy blocked at TESDA premises.
- Bronio’s Motion to Quash execution; Abragar’s application for break-open order.
- TESDA’s Intervention (Sept. 25, 2007): TESDA moved to quash execution, alleging Marble Center is a non-juridical entity under a MOA among TESDA, DTI, MAP, and Bulacan Province, and real parties-in-interest were not impleaded.
- NLRC Resolution (June 30, 2008): Granted TESDA’s intervention, vacated LA decision, writ of execution, and break-open order; remanded for impleader of real parties.
- CA Decision (March 13, 2012): Annulled NLRC resolutions for being filed after LA decision became final; reinstated LA decision.
Issues:
- Fundamental Question
- Did the Court of Appeals err in nullifying the NLRC’s grant of TESDA’s Appeal Memorandum in Intervention on the ground that the writ of execution was final and executory?
- Whether the Marble Center’s lack of juridical personality and the non-joinder of indispensable parties rendered the proceedings void ab initio.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)