Case Summary (G.R. No. 160905)
Case Background
Bienvenido D. Goma filed a complaint for illegal dismissal, underpayment of wages, non-payment of premium pay for holidays and rest days, five days incentive leave pay, damages, and attorney's fees against Pamplona Plantation Incorporated. Goma asserted that he was a regular employee working as a carpenter from 1995 until 1997, at which point he allegedly received no work assignment, leading him to claim illegal dismissal.
Respondent's Position
Pamplona Plantation denied Goma's assertions, contending he was hired by the former management and was not its employee. They maintained that Goma was an employee of Pamplona Plantation Leisure Corporation (PPLC), created for a different business purpose, and argued that Goma’s work was project-based, not regular employment.
Labor Arbiter's Decision
On June 28, 1999, the Labor Arbiter dismissed Goma’s case for lack of merit, concluding that he was not an employee of Pamplona Plantation and dismissed his claims for monetary compensation.
NLRC Ruling
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, asserting that Goma was indeed a regular employee and entitled to reinstatement, backwages, and benefits. The NLRC highlighted the lack of evidence from the respondent to refute Goma's claims and supported the existence of an employer-employee relationship.
Court of Appeals Decision
Pamplona Plantation sought a certiorari review in the Court of Appeals (CA), which granted their petition and annulled the NLRC's decision. The CA identified gaps in Goma's evidence, ruling that he failed to definitively prove the employer-employee relationship. It concluded that since employment contracts are binding only between the contracting parties, Goma’s claim was invalid as he was employed by the former owner.
Supreme Court's Review
Goma petitioned the Supreme Court to review the CA’s ruling. The Court identified three central issues: the nature of Goma's employment status with the respondent, the legality of his dismissal, and his entitlement to monetary claims.
Employment Status Determination
The Supreme Court determined that Goma was indeed a regular employee. Under Article 280 of the Labor Code, an employee is deemed regular when engaged in activities that are necessary or desirable for the business, regardless of the duration of such activities. The Court noted that Goma had worked for two years and performed essential carpentry tasks within the respondent’s business operations.
Illegality of Dismissal
The Court found that Goma’s dismissal was illegal as it did not meet the requirements of substantive and procedural due process. Regular employees can only be dismissed for just causes but must be afforded the proper notification and hearing. Goma’s lack of work assignment amounted to illegal dismissal, with no evidence from Pamplona P
...continue readingCase Syllabus (G.R. No. 160905)
Case Overview
- The case involves a petition for review filed by Bienvenido D. Goma against Pamplona Plantation Incorporated concerning illegal dismissal and various monetary claims.
- The Decision of the Court of Appeals (CA) dated August 27, 2003, granted the respondent's petition for certiorari, reversing the favorable ruling of the National Labor Relations Commission (NLRC).
Background of the Case
- Petitioner Goma filed a complaint for illegal dismissal, underpayment of wages, non-payment of premium pay, incentive leave pay, damages, and attorney's fees with the Sub-Regional Arbitration Branch No. VII in Dumaguete City.
- Goma claimed he worked as a carpenter for the respondent since 1995, with a daily wage of ₱90.00, and alleged he was illegally dismissed when the respondent failed to assign him work from 1997 onwards.
Respondent's Defense
- The respondent denied hiring the petitioner as a regular employee, asserting that Goma was employed by the previous owner of the hacienda and was not its responsibility.
- They contended that Goma's work was related to the construction of facilities for a new corporation, Pamplona Plantation Leisure Corporation (PPLC), and that he was only a project employee.
Labor Arbiter's Decision
- The Labor Arbiter dismissed Goma's case for lack of merit on June 28, 1999, concluding that Goma was not an employee of the respondent and thus denied his monetary claims.
NLRC Ruling
- Upon appeal, the NLRC reversed the Labor Arbiter's decision, ruling in favor of Goma, asserting