Case Summary (G.R. No. 254596-97)
Factual Background
The petitioners were hired as riders by Amber Golden Pot Restaurant at various times between 2010 and 2014. On April 30, 2016, Amber entered into a Project Agreement with AMSI to provide necessary workers for its branches. The petitioners claimed they were illegally dismissed on May 19, 2017, without just cause or due process. They filed a complaint against Amber and AMSI for wrongful dismissal, non-payment of wages, illegal deductions, and various damages.
Labor Arbiter's Decision
On April 16, 2018, the Labor Arbiter ruled that the petitioners were illegally dismissed, as Amber had not proven compliance with just cause and due process requirements. The Arbiter found that AMSI was engaged in labor-only contracting, as it did not meet the substantial capital requirement and lacked independent control over the workers' performance. The petitioners were also awarded backwages and refunds for illegal deductions.
Ruling by the National Labor Relations Commission (NLRC)
Affirming the Labor Arbiter's ruling on September 10, 2018, the NLRC held that AMSI had not demonstrated sufficient independence from Amber. The NLRC highlighted that the workers were integral to Amber’s business operations, reinforcing the notion of illegal dismissal due to the absence of proper termination procedures. The NLRC rejected AMSI's submission of additional documents on appeal, stating that the evidence suggested Amber maintained control over the petitioners.
Court of Appeals Decision
The CA partially granted the petitions for certiorari from Amber and AMSI on February 13, 2020, reversing the NLRC's ruling, citing AMSI's status as a legitimate labor contractor based on its registration and adequate capital. The CA concluded that the petitioners failed to prove they'd been dismissed and were thus not entitled to reinstatement or backwages. However, it upheld illegal deductions related to meal expenses, which lacked consent from the petitioners.
Supreme Court Review
The Supreme Court, recognizing the conflicting findings, decided to review the factual issues raised by the parties. It reiterated the nature of labor-only contracting as defined under Article 106 of the Labor Code and determined that AMSI engaged in this practice, failing to operate independently of Amber. The Court emphasized the substantial connection between the petitioners’ work as riders and Amber’s core business operati
...continue readingCase Syllabus (G.R. No. 254596-97)
Case Overview
- The case revolves around a Petition for Review on Certiorari filed by seven petitioners against Amber Golden Pot Restaurant Corporation and Ablebodies Manpower Services, Inc. (AMSI), contesting the decisions of the Court of Appeals (CA) which reversed earlier rulings by the National Labor Relations Commission (NLRC).
- The petitioners claimed illegal dismissal and sought various monetary claims, including backwages and damages, following their dismissal on May 19, 2017.
Background of the Case
- The petitioners were employed as riders by Amber at varying dates from 2010 to 2014.
- On April 30, 2016, Amber entered into a Project Agreement with AMSI, which was to provide workers for various services, including food delivery.
- The petitioners alleged they were dismissed without just cause and due process, with some claiming they were coerced to resign.
Procedural History
- The Labor Arbiter ruled that the petitioners were illegally dismissed and ordered their reinstatement and payment of backwages and other benefits.
- The NLRC upheld the Labor Arbiter's decision in September 2018.
- The CA, in February 2020, partially granted the petitions filed by Amber and AMSI, leading to the petitioners' appeal to the Supreme Court.
Ruling of the Labor Arbiter
- The Labor Arbiter found that AMSI engaged in labor-only contracting, emphasizing that the petitioners performed activities necessary to Amber's business.
- The dismissal was deemed illegal due to insufficient evidence of just cause or compliance with