Case Summary (G.R. No. 153192)
Applicable Law
- Legal Framework: The 1987 Philippine Constitution and the Labor Code of the Philippines, specifically Article 280 regarding the definition of regular and casual employment.
Employment Details
Respondents Bastida and Caban were engaged by Dealco Farms, Inc. as "comboys" responsible for escorting and caring for live cattle transported from General Santos City to Manila. They were hired on June 25, 1993, and October 29, 1994, respectively, and were compensated at P1,500.00 per trip. Their responsibilities included ensuring the welfare of the cattle during transit which lasted an average of 12 days, often making two trips per month.
Facts of Dismissal
On October 15, 1999, Bastida and Caban, alongside Maquinsay and Parrocha, filed a complaint for illegal dismissal against the petitioner, claiming wrongful termination without due process, and claiming various monetary benefits. The context of their dismissal arose after being informed by a company official that they would be replaced due to a decrease in the volume of cattle imports, purportedly without justification.
Contentions of the Parties
The respondents contended they were illegally dismissed, highlighting that their termination lacked just cause and proper notice. Conversely, Dealco Farms contended that respondents were not employees but independent contractors engaged on a “per-trip” basis, arguing that the cessation of employment resulted from decreased demand due to economic conditions and not from any misconduct attributed to the respondents.
Labor Arbiter's Findings
On June 30, 2000, the Labor Arbiter ruled that respondents were employees of the petitioner, determining that all elements of an employer-employee relationship were present, including the control over their work. The Arbiter awarded both respondents separation pay, cost of living allowance (COLA), and a union service fee, while denying claims for backwages and other monetary benefits since the respondents had expressed a desire not to be reinstated.
NLRC Appeal
The NLRC affirmed the Labor Arbiter’s decision, underscoring the established employer-employee relationship and the monetary awards granted. It emphasized the control exercised by Dealco Farms over the respondents during their employment, further rejecting petitioner’s assertions regarding the nature of the employment and the role of middlemen in livestock shipping.
Court of Appeals
Dealco Farms subsequently appealed to the Court of Appeals to challenge the NLRC’s ruling. However, the appellate court dismissed the petition for certiorari due to procedural deficiencies, notably the failure to attach essential documents and provide an adequate explanation for the mode of service employed in filing the petition.
Supreme Court Review
The Supreme Court upheld the dismissal by the Court of Appeals, agreeing that the petition lacked the necessary documentation
...continue readingCase Syllabus (G.R. No. 153192)
Case Overview
- This case involves a review of the Resolutions of the Court of Appeals (CA) in CA-G.R. SP No. 68972, which denied the petition for certiorari filed by Dealco Farms, Inc. (petitioner) challenging the decision of the National Labor Relations Commission (NLRC).
- The petitioner is engaged in the importation, production, fattening, and distribution of live cattle, primarily serving meat dealers and processors in Mindanao and Metro Manila.
- Respondents, Chiquito Bastida and Albert Caban, were hired as "comboys" to escort cattle during transit from General Santos City to Manila.
Background of the Case
- Respondents were employed as escorts starting on June 25, 1993, and October 29, 1994, responsible for the care of the cattle during transport, including feeding and ensuring their safety.
- Each respondent was compensated P1,500.00 per trip, which typically lasted around 12 days, with two trips made per month.
- On October 15, 1999, the respondents filed a complaint for illegal dismissal against the petitioner, along with claims for various monetary benefits.
Procedural History
- The Labor Arbiter found in favor of the respondents, establishing an employer-employee relationship and granting monetary awards, including separation pay and cost of living allowance (COLA).
- The NLRC affirmed the Labor Arbiter’s decision, which led the petitioner to file a petition for certiorari with the CA, alleging procedural flaws in the dismissal of their case.
- The CA dismissed the petition due to non-compliance with procedural requirements, prompting the current appeal.