Case Summary (G.R. No. 222523)
Facts of the Case
Culla was employed by the Tanongon spouses in various roles, including mechanic, manager, and dispatcher, earning a monthly salary of ₱5,000 plus commissions. He claimed to have been unlawfully dismissed and ejected from his residence in June 1986, with no prior investigation or written notice. In response to his dismissal, he filed a complaint for reinstatement, backwages, commissions, and damages.
Allegations and Denials
The Tanongon spouses contended that they did not operate the taxi service directly and denied any employer-employee relationship with Culla. They claimed he acted as an independent contractor while Aida dela Cruz stated that Culla was never officially hired by her and questioned any entitlement to a commission on earnings.
Labor Arbiter's Decision
On February 14, 1990, Labor Arbiter Ricardo C. Nora ruled that Culla was an employee of the Tanongon spouses and was terminated illegally. The Labor Arbiter ordered the spouses and Aida dela Cruz to pay Culla ₱195,000 in backwages and separation pay. However, the request for a 15% commission was denied due to a lack of evidence.
Appeals and NLRC Rulings
Both parties appealed the Labor Arbiter’s decision. Culla sought greater monetary compensation while the Tanongon spouses disputed Culla's status as an employee. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, citing late filing of appeal by the Tanongon spouses and a lack of evidence supporting Culla's commission claim.
Consolidated Petitions for Certiorari
Culla and the Tanongon spouses filed separate petitions for certiorari, which were consolidated. Culla's argument that his monthly salary was partial fulfillment of a commission agreement was dismissed as the Statute of Frauds applied. The NLRC’s finding that Culla was indeed an employee was deemed supported by sufficient evidence.
Employment Status and Rights
The case examined Culla's employment status under Article 280 of the Labor Code, establishing that he was regular staff performing necessary activities for the business. As such, he was entitled to security
...continue readingCase Syllabus (G.R. No. 222523)
Case Overview
- The case arises from a petition for certiorari filed by Ludivico C. Culla to annul the decision of the National Labor Relations Commission (NLRC) dated March 5, 1992.
- Culla sought backwages amounting to P195,000.00 and separation pay from Norberto and Dorothea Tanongon, who operate taxicabs under the names "Arms Taxi" and "Lin-lin Taxi."
- The taxicabs are registered under Aida dela Cruz, who holds a certificate of public convenience for the operation of the service.
Background Facts
- Culla was employed by the Tanongon spouses in various roles including mechanic, shop manager, garage caretaker, dispatcher, and liaison man at a monthly salary of P5,000.00, plus commission.
- On June 11, 1986, without Culla's consent, the Tanongon spouses forcibly removed him from his living quarters and took his personal belongings.
- Culla filed a complaint alleging illegal dismissal and unauthorized eviction, claiming that he had not received any prior investigation or written notice regarding the charges against him.
Claims and Defenses
- Culla demanded reinstatement with backwages and a 15% commission on the taxi business's gross income, along with various damages.
- The Tanongon spouses denied the employer-employee relationship and claimed Culla was an independent contractor, asserting that Arms Taxi was owned by Aida dela Cruz.
Labor Arbiter's Decision
- Labor Arbiter Ricardo C. Nora ruled in favor of Culla, affirming his status as an employe