Case Summary (G.R. No. L-5749)
Background of the Case
Aba asserts that his employment at Hda. Sta. Ines commenced on December 26, 1976, continuing until his termination on August 27, 1990, which he claims was due to his union activities. In contrast, the respondents deny his employment, presenting evidence, including a complaint from Aba against a different employer, Hda. Fatima, in which he claimed to have worked from January 5, 1972, until December 6, 1990. They argue that it is implausible for Aba to have been simultaneously employed by two different haciendas located 15 kilometers apart.
Labor Arbiter's Dismissal
Labor Arbiter Geoffrey P. Villahermosa dismissed Aba's complaint on November 17, 1993, due to inconsistencies in Aba's claims regarding his employment periods. Aba subsequently appealed this dismissal, arguing that the cases concerning his employment at Hda. Sta. Ines and his salary disputes with Hda. Fatima should have been consolidated and adjudicated together.
NLRC's Remand and Further Developments
On March 10, 1994, the National Labor Relations Commission (NLRC) remanded the case back to the Labor Arbiter for further factual findings. Upon remand, Aba revised his employment timeline, now claiming he started working at Hda. Sta. Ines in 1968. Nevertheless, the respondents maintained their position that Aba was never their employee, further supporting this claim with affidavits from their personnel.
Further Dismissals and Appeal Issues
The Labor Arbiter dismissed the case again on January 25, 1995, asserting a lack of employer-employee relationship. Aba appealed this dismissal but encountered procedural issues, specifically failing to pay the appeal docketing fee on time, leading to the NLRC dismissing his appeal. Aba made a timely Motion for Reconsideration and subsequently submitted a Supplemental Brief, which the NLRC denied.
Legal Arguments on Appeal Docketing Fee
The Office of the Solicitor General contends that the dismissal of Aba's appeal due to the late payment of the appeal docketing fee contradicts constitutional provisions aimed at labor protection. The petition argues that Aba's appeal had been perfected as he had filed it within the reglementary period, and highlights that no monetary award was involved that required an appeal bond.
Jurisprudence and Labor Code Provisions
The court emphasized that the appeal has been deemed perfected since the necessary conditions had been m
...continue readingCase Syllabus (G.R. No. L-5749)
Case Background
- Wilson Aba filed a complaint against Hda. Sta. Ines and/or Alfonso Villegas alleging illegal dismissal, legal holiday pay, premium pay on holidays and rest days, service incentive leave pay, separation pay, and salary and 13th month differentials.
- Aba claimed to have been employed at Hda. Sta. Ines from December 26, 1976, until his termination on August 27, 1990, asserting that his dismissal was due to union activities.
- Hda. Sta. Ines and Villegas denied the claims, contending that Aba was never employed by them. They pointed to a separate complaint filed by Aba against Hda. Fatima for underpayment of salaries, claiming this indicated overlapping employment periods.
Employment Dispute and Initial Dismissal
- Hda. Sta. Ines and Villegas highlighted the impossibility of Aba working for two employers located 15 kilometers apart at the same time.
- On November 17, 1993, Labor Arbiter Geoffrey P. Villahermosa dismissed Aba's complaint with prejudice due to inconsistencies in his employment claims.
- Aba appealed, arguing the complaints should be consolidated as they involved different issues: illegal dismissal versus unpaid salaries.
Remand and Subsequent Developments
- The National Labor Relations Commission (NLRC) remanded the case on March 10, 1994, for a merits decision, citing unresolved factual matters.
- Upon remand, both parties submitted position papers. Aba altered