Title
Cabe vs. Tumang
Case
G.R. No. 57682
Decision Date
Mar 18, 1985
The Cabes hired Tamayo to build a house but dismissed him for deviating from plans. Tamayo filed a labor claim, but the Supreme Court ruled he was an independent contractor, not an employee, and labor tribunals lacked jurisdiction.

Case Summary (G.R. No. 57682)

Facts of the Case

In March 1979, Samuel Tamayo entered into a contract with Ronald and Purita Cabe to construct their residential house for a total cost of P106,000, adhering to architectural plans and specifications. During the execution of this contract, the Cabes terminated Tamayo's services due to alleged deviations from the agreed plans. Subsequently, the construction of the house was completed by other workers.

Legal Proceedings Initiated by Tamayo

On June 28, 1979, Tamayo filed a complaint with the Regional Office of the Department of Labor in Laoag City, seeking to recover P7,000 for payment of labor and materials. He claimed these amounts as a head carpenter on behalf of his 18 co-workers, whose wages he had advanced, alongside his reimbursement for materials purchased during the construction process.

Decision of the Assistant Regional Director

The Assistant Regional Director for Arbitration ruled in favor of Tamayo, ordering the Cabes to pay him P6,400 in contractual wages and P600 in reimbursement for materials. This ruling was contested by the Cabes through a certiorari petition, asserting that the Assistant Director had acted without proper jurisdiction in rendering the decision.

Jurisdictional Issues

The central issue in this case pertains to whether the Labor Regional Office possessed the jurisdiction to entertain Tamayo's complaint. The Supreme Court determined that Tamayo operated as an independent contractor, distinguishing his status from that of an employee. As such, the claims made by Tamayo did not fall within the jurisdiction of the Labor Regional Office or the National Labor Relations Commission. The relevant legal provisions, specifically Article 217 of the Labor Code, restrict the jurisdiction of these bodies to disputes arising strictly from an employer-employee relationship.

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