Case Summary (G.R. No. 225914)
Applicable Law
The legal grounding includes the provisions of the 1987 Philippine Constitution, as well as labor laws and the parameters set forth in Department of Labor and Employment (DOLE) Department Order No. 19, Series of 1993, which outlines the indicators of project employment in the construction industry.
Procedural History
The case unfolds through two significant complaints lodged by the private respondents against the petitioners. The first case, involving claims for unpaid wages and benefits, was dismissed by Labor Arbiter Adela S. Damasco on the grounds of insufficient evidence. Upon appeal, the CA reversed this decision, affirming that the private respondents were indeed project employees for wage claims but did not compute specific amounts due to a lack of records.
In the second case, initiated by private respondents alleging illegal dismissal, the Labor Arbiter ruled that the petitioners had failed to substantiate their claim that the respondents were project employees, declaring them regular employees who had been illegally dismissed.
Issue of Res Judicata
The petitioners asserted that the CA had erred by not recognizing the doctrine of res judicata, as the earlier CA ruling had deemed the respondents as project employees. The CA, however, clarified that the two cases did not share identical causes of action. Res judicata, applied as "bar by prior judgment," would not prevent re-litigation since the issues adjudicated in the first case were distinct from those in the second case.
Employment Status Determination
The Labor Arbiter's decision hinged on various factors to determine whether the private respondents were regular or project employees. The criteria outlined in DOLE Department Order No. 19 were not satisfactorily met by the petitioners, who failed to provide evidence that delineated the scope and duration of employment for each respondent. Consequently, the CA and the Labor Arbiter ruled that the respondents were regular employees entitled to security of tenure.
Due Process in Dismissal
The court found that the petitioners had failed to provide just cause for the dismissals, and furthermore, did not adhere to the procedural requirements set forth by labor laws for terminating regular employees. Thus, the private respondents were deemed to have been illegally dismissed, and their entitlement to reinstatement and backwages was affirmed.
Damages and Fees
The CA awarded private respondents moral and exemplary damages, alongside attorney's fees amounting to 10% o
...continue readingCase Syllabus (G.R. No. 225914)
Background of the Case
- This case involves a petition for certiorari under Rule 65 by petitioners Square Meter Trading Construction and its sole proprietor Lito C. Pascual against the Court of Appeals' (CA) Decision dated February 24, 2016, and Resolution dated June 8, 2016, in CA-G.R. SP No. 130349.
- The petitioners allege grave abuse of discretion amounting to lack or excess of jurisdiction, particularly invoking the doctrine of res judicata.
- The primary contention arises from conflicting judicial determinations regarding the employment status of private respondents, which were previously found to be project employees in an earlier case (CA-G.R. SP No. 124979) but ruled as regular employees in the current case.
Parties Involved
- Petitioners: Square Meter Trading Construction and Lito C. Pascual, who are engaged in the construction industry.
- Private Respondents: Ricardo Gallano, Felimon Francisco, Oscar Borja, and others who were previously employed by the petitioners.
Procedural History
- Initial Complaints: Private respondents filed two complaints against petitioners:
- The first (NCR-02-02511-11) in February 2011 for underpayment of wages and benefits from 2007-2010, which was dismissed due to lack of merit.
- The second (NCR-04-06754-11) in April 2011 for illegal dismissal and unfair labor practices, which was consolidated with another complaint by the Philippine Association of Free Labor Union (PAFLU).
Findings of the Labor Arbiter
- In the first case, Labor Arbiter Adela S. Damasco found that:
- The private respondents were construction workers engaged