Case Digest (G.R. No. 219755) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 219755, decided on April 18, 2022 under the 1987 Constitution, petitioners Richard N. Wahing, Ronald L. Calago, and Pablo P. Mait worked as rubber tree tappers on the plantation of respondents Spouses Amador and Esing Daguio in Cagayan de Oro. On October 15, 2006, Mait was ordered to “stop tapping the rubber tree,” and on February 6, 2007, Wahing and Calago received the same directive. The trio filed a complaint for illegal dismissal, underpayment of wages, benefits, damages, and attorney’s fees before the Labor Arbiter, who dismissed the case on the ground that their relationship was landlord-tenant, not employer-employee. On appeal, the National Labor Relations Commission (NLRC) vacated that dismissal and remanded for a full merits hearing. After the Daguio Spouses twice failed to submit position papers, the Labor Arbiter ruled on September 28, 2010 that petitioners were illegally dismissed and awarded them ₱777,090.52. The Daguio Spouses appealed but the NLRC set Case Digest (G.R. No. 219755) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners Richard N. Wahing, Ronald L. Calago and Pablo P. Mait (rubber tappers) worked on the Daguio Spouses’ rubber plantation.
- Mait was ordered to stop tapping on October 15, 2006; Wahing and Calago received similar orders on February 6, 2007.
- Procedural History
- Labor Arbiter: dismissed illegal dismissal complaint, concluding the relationship was landlord–tenant, not employer–employee.
- NLRC (First): set aside the dismissal and remanded to the Labor Arbiter for a decision on the merits.
- Labor Arbiter: issued September 28, 2010 Decision finding illegal dismissal and awarding ₱777,090.52.
- NLRC (Second): remanded again for the spouses’ evidence after partial reduction of appeal bond.
- Court of Appeals: in CA-G.R. SP No. 04746-MIN, dismissed the complaint on the merits for lack of employer–employee relationship.
- This Supreme Court Petition for Review on Certiorari challenges the CA’s Decision and Resolution.
Issues:
- Procedural Issues
- Whether the CA gravely erred in resolving merits not raised in the petition for certiorari.
- Whether respondents perfected their appeal to the NLRC by posting the required bond.
- Substantive Issues
- Whether an employer–employee relationship existed between petitioners and the Daguio Spouses.
- Whether petitioners were illegally dismissed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)