Case Digest (G.R. No. 209418)
Facts:
W.M. Manufacturing, Inc. v. Richard R. Dalag and Golden Rock Manpower Services, G.R. No. 209418, December 07, 2015, Supreme Court Third Division, Velasco Jr., J., writing for the Court.On January 3, 2010, W.M. Manufacturing, Inc. (WM MFG) (client) and Golden Rock Manpower Services (contractor) executed a Service Agreement under which Golden Rock would "render, undertake, perform and employ the necessary number of workers as the CLIENT may need" and which expressly disclaimed an employer-employee relationship between the client and the contractor’s assignees. On April 26, 2010 Golden Rock engaged Richard R. Dalag as a contractual factory worker to be assigned to WM MFG; the parties signed a five-month Employment Contract defining Dalag as a "contractual employee" and allowing termination for enumerated causes.
Despite the five-month term, WM MFG security prevented Dalag from reaching his workstation on August 7, 2010; Dalag was escorted to the locker room and allowed only to withdraw his belongings. Dalag filed a complaint for illegal dismissal (LAC No. 03‑000673‑11), alleging he was terminated without notice or hearing, that his work was necessary and directly related to WM MFG’s business (thus establishing regular status), and that Golden Rock was a labor‑only contractor. WM MFG and Golden Rock countered that Dalag abandoned his work and submitted several memoranda accusing him of repeated failures to report machine problems and of taking spare parts.
The Labor Arbiter (LA) Eduardo G. Magno, in a January 24, 2011 Decision, dismissed Dalag’s complaint for lack of merit but awarded unpaid wages for three days (P1,212), finding Dalag failed to prove he was actually dismissed and treating Golden Rock as his employer. Dalag appealed to the National Labor Relations Commission (NLRC).
On May 31, 2011 the NLRC reversed the LA and declared Dalag illegally terminated, finding WM MFG to be the true employer and that the relation between WM MFG and Golden Rock was labor‑only contracting under the control test; it ordered reinstatement with backwages (computed at P107,739.73) and awarded unpaid wages. WM MFG and Watson Nakague moved for reconsideration and attached for the first time Golden Rock’s DOLE Certificate of Registration and the Service Agreement.
On September 20, 2011 the NLRC granted reconsideration, reinstating the LA’s decision on the ground that the belatedly‑offered documents showed Golden Rock to be a legitimate contractor and that Dalag had not established actual dismissal; the Commission applied the four‑fold test and considered payment of wages and contractual terms. Dalag filed a Rule 65 petition for certiorari with the Court of Appeals (CA), arguing the NLRC committed grave abuse by admitting belated evidence and reversing its earlier ruling.
The CA, in a February 21, 2013 Decision (later amended September 17, 2013), granted Dalag’s petition, reinstated the NLRC’s May 31, 2011 Decision (but in the Amended Decision absolved company officers Nakague and Pablo Ong of personal liability), and held that procedural rules and evidence rules should be liberally applied in labor cases; the CA found Golden Rock failed to prove the requisites of a legitimate manp...(Subscriber-Only)
Issues:
- Was Dalag excused from filing a motion for reconsideration before petitioning for certiorari under Rule 65?
- Did WM MFG and Golden Rock engage in labor‑only contracting?
- Was Dalag illegally dismissed?
- What monetary awards, if any, is Dalag entitled to...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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