Case Summary (G.R. No. 250987)
Applicable Law
The case is governed by the Labor Code of the Philippines, particularly concerning the security of tenure of employees, illegal dismissal, payment of benefits such as service incentive leave and 13th month pay, as well as applicable jurisprudence regarding labor disputes.
Nature of Employment and Claims
Guinto filed a complaint asserting his employment with the respondents since August 1997, arguing that he held a position as a "sizer," which is integral to the respondents' business operations. Following his termination in November 2015, a series of communications ensued, culminating in his formal complaint seeking illegal dismissal relief and monetary compensation, including separation pay and attorney's fees.
Respondents' Defense
Respondents challenged the claim of an employer-employee relationship, insisting that Guinto operated exclusively as a porter at the Orani Fishport and was not their employee. They provided evidence, including affidavits from other porters and their business permits indicating only two regular employees, to dispute Guinto’s claims.
Ruling of the Labor Arbiter (LA)
The Labor Arbiter ruled in favor of Guinto, finding that he was indeed an employee of the respondents, primarily relying on a Certification from Angelo Salangsang. However, the LA also determined that Guinto had been illegally dismissed, ordering the payment of his back wages, separation pay, and other benefits.
Ruling of the National Labor Relations Commission (NLRC)
The NLRC upheld the finding of an employer-employee relationship but reversed the LA's determination of illegal dismissal. The NLRC concluded that Guinto failed to substantiate his claim of dismissal, leading to the order to reinstate him without back wages and granting him service incentive leave pay.
Decision of the Court of Appeals (CA)
The CA affirmed the NLRC's decision, finding no basis to overturn the latter's ruling regarding the absence of evidence proving illegal dismissal. It recognized Guinto’s entitlement to service incentive leave pay but denied 13th month pay, citing his commission-based compensation.
Supreme Court Ruling
Upon reviewing the petitions, the Supreme Court found that the CA failed to identify grave abuse of discretion by the NLRC when it dismissed Guinto's illegal dismissal claim. The Court h
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Case Background
- This case is a Petition for Review on Certiorari, G.R. No. 250987, dated March 29, 2022.
- The petitioner, Noel G. Guinto, contests the decision dated May 24, 2019, and the resolution dated December 12, 2019, of the Court of Appeals (CA) in CA-G.R. SP No. 157156.
- The CA upheld the National Labor Relations Commission (NLRC) decisions that reversed the Labor Arbiter's (LA) ruling, dismissing Guinto's illegal dismissal claim.
Antecedents of the Case
- Guinto filed a complaint for illegal dismissal on February 6, 2017, against Sto. NiAo Long-Zeny Consignee, its owner Angelo Salangsang, and manager Zenaida Salangsang.
- The complaint was later amended to include claims for unpaid service incentive leave and 13th month pay.
- Guinto alleged he was employed since August 1997, initially as a warehouseman and later as a "sizer" of aquatic animals.
- He claimed that on November 27, 2015, Zenaida verbally instructed him to stop coming to work, which he interpreted as termination.
Claims and Evidence Presented
- Guinto provided several pieces of evidence to support his claim of employment:
- A certification from Angelo stating Guinto's employment status.
- Work schedules, payslips, and affidavits from co-workers affirming his employment.
- Respondents denied that Guinto was their employee, asserting that he was merely a porter at the Orani Fishport.
Labor Arbiter's Decision
- The LA ruled in favor of Guinto, confirming his status as a regular employee based on the certification and other evidence.
- The LA found that Guinto was illegally dismissed and awarded him backwages, separation pay, service incentive leave pay, and attorney's fees.
NLRC Ruling
- Upon