Case Summary (G.R. No. 237277)
Applicable Law
The decisions in this case are grounded on the 1987 Philippine Constitution and, more specifically, on provisions of the Labor Code of the Philippines that govern employment relations, contracting, and disputes arising from such relationships.
Procedural History
Several appeals were consolidated under various G.R. Numbers, notably G.R. Nos. 237277, 237317, 232718, 238965, and 256753. The petitions addressed the legality of contracts, employment relationships, and previous rulings by lower courts including the Labor Arbiter and Court of Appeals (CA). In particular, complaints of illegal dismissal were filed and contested through various legal procedural avenues, culminating in appeals to the Supreme Court.
Findings on Employment Relationships
In G.R. Nos. 237277 and 237317, Alaska, as an employer, engaged Asiapro and 5S Manpower for labor services. The Court found that Asiapro operated as a legitimate contractor with a proven independent business and a substantial client base, while 5S Manpower was deemed engaged in labor-only contracting, lacking sufficient capital and a diverse clientele. Thus, employees assigned through 5S Manpower were considered regular employees of Alaska due to this classification.
Illegal Dismissal Rulings
The Court ruled that employees Bate, Combite, and Oliver were unlawfully dismissed after their contracts with 5S Manpower expired, declaring that they were entitled to reinstatement and back wages. Conversely, Medrano and Paez were found not to have been dismissed, as they opted not to be reassigned after their contracts ended, thereby dismissing their illegal dismissal claims.
Review of Labor Arbiter Decisions
The appeals in G.R. No. 232718 confirmed that the workers were indeed misclassified, with the Court reaffirming Asiapro’s legitimacy, while the CA's previous decision that reversed labor arbiter findings was sufficiently substantiated. Complaints of illegal dismissal against Alaska were dismissed as the CA identified Asiapro as the true employer with proper labor practices.
Execution of Prior Rulings
In G.R. No. 256753, the Court upheld the immediate implementation of the labor arbiter’s order of reinstatement, refuting Alaska's argument of automatic suspension of execution upon appeal. The Court underscored the non-negotiable obligation to reinstate employees while appeals were ongoing unless legally restrained.
Rulings on Additional Claims
Additionally, in G.R. No. 238965, the Court evaluated claims made by Rosales, et al., contending they faced illegal dismissal through
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Parties and Case Background
- Alaska Milk Corporation (Alaska), a domestic corporation manufacturing dairy products, and Asiapro Multi-Purpose Cooperative (Asiapro), a registered cooperative contracting out services of its worker-members, filed consolidated petitions.
- Respondents Ruben P. Paez, Florentino M. Combite, Jr., Sonny O. Bate, Ryan R. Medrano, and John Bryan S. Oliver (collectively Paez, et al.) worked as production helpers at Alaska's Laguna Plant.
- Joint Operating Agreements existed between Alaska, Asiapro, and 5S Manpower Services Cooperative (5S Manpower), providing workers who performed auxiliary functions.
- Paez, et al. were informed of termination of assignments in 2013; Paez and Medrano wanted transfer to different principal through Asiapro, while Bate, Combite, and Oliver requested transfer through 5S Manpower.
- Before action, Paez, et al. filed complaints for illegal dismissal, regularization, and payment claims.
Labor Arbiter and NLRC Findings
- Labor Arbiter dismissed the complaints, finding Asiapro and 5S Manpower legitimate labor contractors controlling the workers through coordinators.
- Paez, et al. were not Alaska employees; designations and terminations were lawful.
- NLRC affirmed Labor Arbiter's decision entirely.
Court of Appeals (CA) Decision
- CA ruled that Asiapro and 5S Manpower engaged in labor-only contracting.
- Declared Paez, et al. regular employees of Alaska.
- Found that lack of capital investment by Asiapro and 5S Manpower evidenced labor-only contracting.
- Decreed Paez, et al. were illegally dismissed.
Supreme Court Decision (Nov. 27, 2019)
- Reversed the CA rulings.
- Ruled Asiapro as a legitimate job contractor with substantial capital, longstanding operation, and diversified clientele.
- Found 5S Manpower failed to prove substantial capital or multiple clients; concluded labor-only contracting.
- Bate, Combite, Oliver deemed regular employees of Alaska and illegally dismissed; ordered reinstatement with full backwages and benefits.
- Paez and Medrano were not illegally dismissed as they refused reassignment after contract expiration; complaints dismissed.
Motions for Reconsideration
- Alaska Milk Corporation filed a Motion for Partial Reconsideration asserting 5S Manpower's legitimacy based on capital and compliance with DOLE Department Order No. 18-A.
- Paez, et al. filed a Motion for Reconsideration insisting labor-only contracting elements existed, entitling them to reinstatement with damages and attorney's fees.
- Supreme Court denied both motions for lack of new grounds, affirming its prior decision.
Additional Petitions and Consolidations
- Related cases involving Gilbuena, et al. (G.R. No. 232718), Rosale