Case Digest (G.R. No. 200094) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves a petition for review on certiorari filed by Benigno M. Vigilla and several other petitioners against the Philippine College of Criminology, Inc. (PCCr) and Gregory Alan F. Bautista. The case was decided by the Supreme Court of the Philippines on June 10, 2013, following prior decisions by the Court of Appeals and the National Labor Relations Commission (NLRC). The petitioners, consisting of janitors and maintenance personnel, had previously filed complaints against the respondents, arguing that the dismissed employees were in fact employees of PCCr, despite being informed they were employed by Metropolitan Building Services, Inc. (MBMSI).
The events leading up to the case began in March 2009, when PCCr terminated its relationship with MBMSI due to the revocation of MBMSI's Certificate of Incorporation. Following their termination, the petitioners filed for illegal dismissal among other claims, asserting direct employer-employee relations with PCCr. Howe
Case Digest (G.R. No. 200094) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- This case is a petition for review on certiorari filed under Rule 45 of the Rules of Court.
- The petition challenges the decision of the Court of Appeals (CA) in CA-G.R. SP No. 120225, which affirmed resolutions by the National Labor Relations Commission (NLRC) based on prior findings of a Labor Arbiter (LA).
- Parties and Employment Arrangement
- Petitioners: Benigno M. Vigilla, Alfonso M. Bongot, Roberto Callesa, Linda C. Callo, Nilo B. Camara, Adelia T. Camara, Adolfo G. Pinon, John A. Fernandez, Federico A. Callo, Maxima P. Arellano, Julito B. Costales, Samson F. Bachar, Edwin P. Damo, Renato E. Fernandez, Genaro F. Callo, Jimmy C. Aleta, and Eugenio Salinas.
- Respondents: Philippine College of Criminology Inc. (PCCr) and/or Gregory Alan F. Bautista.
- Employment Facts:
- Petitioners were engaged as janitors, janitresses, and a supervisor in the Maintenance Department of PCCr.
- They were led to believe that their employment relationship was with Metropolitan Building Services, Inc. (MBMSI)—a labor-only contractor—under the supervision of PCCr’s Senior Vice President for Administration, Atty. Florante A. Seril (who also headed MBMSI).
- Discovery and Termination of the Contractual Relationship
- In 2008, PCCr discovered that MBMSI’s Certificate of Incorporation had been revoked effective July 2, 2003.
- Citing the revocation, on March 16, 2009, PCCr terminated its relationship with MBMSI.
- As a result, petitioners (except for one retired employee, Alfonso Bongot) were dismissed from service.
- Claims, Allegations, and Document Submission
- Petitioners initially filed complaints for illegal dismissal, seeking reinstatement and various monetary benefits (back wages, separation pay, underpayment of salaries, overtime, holiday pay, service incentive leave, and 13th month pay).
- They contended that:
- PCCr was the real principal employer controlling the means and methods of work.
- MBMSI was merely a labor-only contractor or an alter ego with no independent employment relationship.
- Their dismissal was executed in bad faith.
- PCCr presented notarized releases, waivers, and quitclaims—purportedly executed by petitioners—in favor of MBMSI, to demonstrate that the claims had been settled.
- Petitioners later alleged that these documents were forged, although they did not initially dispute their authenticity when first presented.
- Decisions of the Labor Arbiter, NLRC, and CA
- Labor Arbiter’s Decision (July 30, 2010):
- Found PCCr to be the real and direct employer of the petitioners.
- Identified MBMSI as a mere adjunct or alter ego acting as a labor-only contractor.
- Determined that petitioners were regular employees and that their dismissal was in bad faith.
- Ordered reinstatement (except for the retired employee) along with the award of back wages, separation/retirement pay, service incentive leave, moral and exemplary damages, and attorney’s fees.
- NLRC Resolutions (February 11, 2011 and April 28, 2011):
- Upheld the LA’s decision by affirming PCCr’s liability; however, they excused respondents from liability on account of the releases, waivers, and quitclaims executed by petitioners.
- Court of Appeals:
- Denied petitioners’ petition for certiorari under Rule 65, affirming the NLRC resolutions.
- Relying on the principle of solidary liability and the presumption of authenticity conferred by notarization, the CA sustained the NLRC’s finding that petitioners had settled their claims by executing the disputed documents.
Issues:
- Authenticity and Execution of Documents
- Did petitioners actually execute the releases, waivers, and quitclaims in favor of MBMSI?
- To what extent can the unchallenged notarization of these documents be relied upon, given the later allegations of forgery?
- Legal Effect of the Releases, Waivers, and Quitclaims
- Did the executed instruments amicably settle the petitioners’ claims against the respondents?
- How should the doctrine of solidary liability affect the extinguishment of liability for PCCr when such releases are in play?
- Corporate Status and Liability of MBMSI
- Can a corporation, whose Certificate of Incorporation has been revoked (i.e., MBMSI), validly execute agreements that affect its liabilities?
- Does the three-year winding-up period under Section 122 of the Corporation Code permit MBMSI to enter into such agreements even after dissolution?
- Scope of Solidary Liability in Labor-Only Contracting
- Is there solidary liability between a labor-only contractor (MBMSI) and the principal employer (PCCr) under the applicable provisions of the Labor Code and Civil Code?
- What is the impact on petitioners’ claims against PCCr given the purported settlement via the executed documents?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)