Title
Yanson vs. Secretary of the Department of Labor and Employment
Case
G.R. No. 159026
Decision Date
Feb 11, 2008
The Philippine Supreme Court denies Mrs. Alberta Yanson's petition, upholding the decision of the Department of Labor and Employment to pay labor standard benefits to 41 workers, citing lack of due process and an employment relationship.
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Case Digest (G.R. No. 159026)

Facts:

  • Mrs. Alberta Yanson, owner of Hacienda Valentin-Balabag, is the petitioner.
  • The Secretary of the Department of Labor and Employment (DOLE) and 41 workers of the hacienda are the respondents.
  • On March 27, 1998, Mardy Cabigo and 40 other workers filed a request for payroll inspection with the DOLE Bacolod District Office, alleging labor law violations by Yanson.
  • An inspection on May 27, 1998, revealed underpayment of wages, non-payment of 13th month pay, non-payment of Social Amelioration Bonus (SAB), and non-payment of the employer's 1/3 carabao share.
  • DOLE Bacolod issued a Notice of Inspection Report and directed Yanson to correct these violations within ten days.
  • Yanson did not appear or submit documents despite notices of hearing and a subpoena duces tecum.
  • On August 12, 1998, DOLE Bacolod issued a Compliance Order directing Yanson to pay P9,084.00 to each of the 41 workers, totaling P372,444.00, and to correct occupational safety and health standards violations.
  • A Writ of Execution was issued on December 17, 1998, to enforce the Compliance Order.
  • Yanson filed a motion opposing the writ, claiming lack of due process and denying the employment relationship with the workers. This motion was denied.
  • Her appeal to the Secretary of Labor was dismissed for insufficient appeal bond.
  • The Court of Appeals (CA) affirmed the dismissal, leading to Yanson's petition for review on certiorari to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court denied Yanson's petition, affirming the decision of the Court of Appeals and the Secretary of Labor.
  2. The Court held that the Compliance Order was validly issued and that Yanson was properly notified.
  3. The Court ruled that the appeal bond requirement under Article 128(b) of the Labor Code is mandatory and cannot be reduced based o...(Unlock)

Ratio:

  • The Supreme Court emphasized that the posting of the proper amount of the appeal bond under Article 128(b) of the Labor Code is mandatory for the perfection of an appeal from a monetary award in labor standard cases.
  • The law does not allow for the reduction of the appeal bond based on the...continue reading

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