Case Digest (G.R. No. 252783)
Facts:
The Redsystems Company, Inc. v. Eduardo V. Macalino, et al., G.R. No. 252783, September 21, 2022, Supreme Court Second Division, Lopez, J., writing for the Court. Petitioner The Redsystems Company, Inc. (TRCI) contracted with Coca‑Cola FEMSA Philippines, Inc. (now Coca‑Cola Beverages Philippines, Inc.) to provide distribution, delivery, hauling and transportation services, and separately entered into service agreements with Macslink‑PSV Services, Inc. (Macslink) to supply personnel to assist TRCI’s operations. Respondents Eduardo V. Macalino, Danilo Tolentino, Axel Pangilinan, Leonardo Santos, Jr., Crisanto Tabago, Noel Tagaro, Gerald Balmores, Gerome Balmores and R‑Jay Vidad (collectively, Macalino et al.) were engaged by Macslink and assigned to Coca‑Cola facilities as pickers and segregators.In March 2017 Macslink ceased operations and dismissed Macalino et al. (among others). Twenty‑four former workers filed complaints with the Labor Arbiter (LA) seeking reinstatement, backwages, regularization and various statutory and contractual benefits. In a Decision dated December 28, 2018, the LA (Labor Arbiter Ma. Bernardita L. Carreon) granted the claims of those complainants who filed position papers, found that TRCI was a labor‑only contractor and that Coca‑Cola was the true employer, and ordered reinstatement and monetary awards including backwages, service incentive leave pay, 13th month pay, overtime pay, moral and exemplary damages and attorney’s fees.
TRCI filed a partial appeal before the National Labor Relations Commission (NLRC), contesting the labor‑only contractor finding and asserting its status as an independent contractor supported by registration, corporate papers and financial statements, and claiming control over its workers. In a Resolution dated March 25, 2019, the NLRC denied TRCI’s appeal for failure to perfect it under Sections 4 and 6, Rule VI of the NLRC Rules of Procedure and Article 223 (now Article 229) of the Labor Code — TRCI paid only appeal and research fees (P520.00) but did not post the cash or surety bond equivalent to the LA’s monetary award (P545,051.03). TRCI’s motion for reconsideration was denied on May 31, 2019.
TRCI then filed a petition for certiorari with the Court of Appeals (CA) alleging grave abuse of discretion by the NLRC. In a Resolution dated November 7, 2019, the CA dismissed the petition for failing to show grave abuse, agreeing that TRCI did not perfect its appeal by posting the required bond; TRCI’s motion for reconsideration was denied on June 15, 2020. TRCI sought review here under Rule 45, arguing that the appeal bond requirement applies only to an employer and that the LA did not declare TRCI the employer or hold it liable for the monetary award.
Respondents pointed out that Coca‑Cola filed and had its own appeal given due course by the...(Pro-only)
Issues:
- Did the Court of Appeals correctly hold that the NLRC did not commit grave abuse of discretion in dismissing TRCI’s appeal for failure to file the required appea...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)