Case Digest (G.R. No. 219755)
Facts:
Wahing, Richard N. et al. v. Spouses Amador and Esing Daguio, G.R. No. 219755, April 18, 2022, Supreme Court Third Division, Leonen, J., writing for the Court.Petitioners Richard N. Wahing, Ronald L. Calago, and Pablo P. Mait (collectively, Wahing et al.) were rubber tree tappers who worked on the plantation of respondents Amador Daguio and Esing Daguio (the Daguio Spouses). Mait was ordered to stop tapping on October 15, 2006, and Wahing and Calago were ordered to stop on February 6, 2007. Petitioners then filed a complaint for illegal dismissal, reinstatement or separation pay, unpaid wages and benefits, damages, and attorney’s fees before the Labor Arbiter.
The Labor Arbiter dismissed the complaint, finding the relationship to be that of landlord and tenant rather than employer-employee. The National Labor Relations Commission (NLRC) vacated that dismissal and remanded the case to the Labor Arbiter for a decision on the merits. After several notices, only petitioners filed position papers; the Labor Arbiter, in a September 28, 2010 Decision, found unlawful dismissal and awarded petitioners P777,090.52 in back wages and benefits.
The Daguio Spouses appealed to the NLRC and challenged receipt of petitioners’ position paper; the NLRC partially granted a motion to reduce the appeal bond and, by an August 24, 2011 Resolution, set aside the Labor Arbiter’s Decision and remanded the case again for reception of respondents’ evidence. Petitioners sought reconsideration, which the NLRC denied. They then filed a petition for certiorari with the Court of Appeals (CA), contending the NLRC lacked jurisdiction because respondents had not perfected their appeal and that due process had already been afforded below.
The Court of Appeals, however, declined to limit its review to procedural points and, on January 23, 2015, reversed the NLRC and dismissed the illegal dismissal complaint on the merits for lack of an employer-employee relationship. Petitioners’ motion for reconsideration before the CA was denied ...(Pro-only)
Issues:
- Did the Court of Appeals gravely err in deciding substantive issues not raised in the petition for certiorari?
- Was there an employer-employee relationship between petitioners and the Daguio Spouses such that petitioners were illeg...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)