Case Summary (G.R. No. 164668)
Factual Background
On November 1, 1990, PLDT and SSCP executed a Security Services Agreement, leading to the assignment of petitioners as security guards at PLDT’s facilities. PLDT terminated this agreement effective October 1, 2001, but petitioners continued to work at their posts, claiming they were directed to do so by PLDT representatives. On September 30, 2002, petitioners’ services were terminated, prompting them to file a complaint for illegal dismissal, asserting they were entitled to various claims including back wages and separation pay.
Labor Arbiter's Decision
The Labor Arbiter ruled in favor of the petitioners, determining they were employees of PLDT, not SSCP. The Arbiter concluded that due process in termination was not followed, as PLDT did not provide the requisite procedural safeguards. The Arbiter ordered PLDT to pay petitioners separation pay and back wages, while denying other claims due to lack of evidence.
Proceedings before the National Labor Relations Commission
PLDT appealed the Labor Arbiter's decision to the National Labor Relations Commission (NLRC), which affirmed the Arbiter's ruling. PLDT's subsequent motion for reconsideration was also denied, leading the company to seek relief from the Court of Appeals.
Court of Appeals Decision
The Court of Appeals ruled in favor of PLDT, setting aside the NLRC’s decision. Applying a four-fold test for employer-employee relationships, the CA determined no such relationship existed, citing that SSCP qualified as an independent contractor with substantial capital. The court based its decision on the terms of the Agreement, which expressly stated that no employer-employee relationship existed between PLDT and the security guards.
Issues Presented
- Whether petitioners maintained an employer-employee relationship with PLDT after the termination of the SSCP contract,
- The application of Article 280 of the Labor Code regarding their employment status,
- The implications of the absence of a renewed contract post-termination,
- The nature of petitioners' thirteen years of service and its impact on their employment classification,
- Whether the CA committed grave abuse of discretion by overturning the labor adjudications favoring the petitioners.
Supreme Court’s Ruling
The Supreme Court granted the petitioners' appeal, determining that an employer-employee relationship existed between PLDT and petitioners following the termination of the SSCP Agreement. The Court found insufficient justification for why petition
...continue readingCase Syllabus (G.R. No. 164668)
The Case
- This Petition for Review on Certiorari under Rule 45 seeks the reversal of the May 6, 2008 Decision and November 4, 2008 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 97398.
- The parties involved are petitioners Raul G. Locsin and Eddie B. Tomaquin against the Philippine Long Distance Telephone Company (PLDT).
- The assailed decision set aside the Resolutions of the National Labor Relations Commission (NLRC) dated October 28, 2005, and August 28, 2006, which upheld the Labor Arbiter's Decision dated February 13, 2004.
- The resolution denied petitioners' motion for reconsideration of the CA's decision.
The Facts
- On November 1, 1990, PLDT entered into a Security Services Agreement with the Security and Safety Corporation of the Philippines (SSCP) for the provision of armed security guards.
- Petitioners Locsin and Tomaquin were among the security guards assigned to a PLDT office.
- On August 30, 2001, PLDT issued a Letter terminating the Agreement effective October 1, 2001.
- Despite the termination, petitioners claimed they were instructed by PLDT representatives to continue securing the premises.
- Petitioners submitted pay slips for January to September 2002, indicating their continued service.
- Their services were ultimately terminated on September 30, 2002, leading to a complaint for illegal dismissal and recovery of various claims against PLDT.
Labor Arbiter's Decision
- The Labor Arbiter found PLDT liable for illegal dismissal, concluding that petitioners were employees of PLDT rather than SSCP, based on their continued service post-termination.
- The Arbiter ruled that PLDT failed to provide substantive and procedural due proces