Case Summary (G.R. No. 203023)
Procedural History
• Labor Arbiter: Dismissed the illegal dismissal complaint, deeming the relationship landlord–tenant.
• NLRC (1st): Vacated and set aside, remanding for reception of evidence and finding illegal dismissal with a P 777,090.52 award.
• NLRC (2nd): Ordered a second remand upon respondents’ appeal.
• Court of Appeals: On certiorari, bypassed procedural defects, ruled on the merits, denied existence of employer–employee relationship, and dismissed the complaint.
• Supreme Court: Petition for Review under Rule 45 followed.
Discretion to Resolve on Merits
Under Rule 51, Section 8 of the Rules of Court and settled exceptions (e.g., matters necessary for a just, complete resolution or to avoid piecemeal justice), the Court of Appeals may address issues not formally assigned. Judicial economy and substantial justice justified its review of both parties’ evidence.
Appeal Bond and Due Process
The posting of a supersedeas bond is ordinarily jurisdictional, yet procedural rules in labor cases may be relaxed to advance substantial justice. The NLRC granted respondents’ motion to reduce bond and they posted an additional P 50,000. Due process was observed by providing notice and opportunity to submit evidence.
Existence of Employer–Employee Relationship
Applying the four‐fold test—power to hire, payment of wages, power to dismiss, power to control—and the two‐tier economic reality test, petitioners proved:
- Daily set wages for fixed working hours.
- Continuous supervision by the Daguio Spouses.
- Risk of dismissal for non-attendance.
- Integral service to the respondents’ rubber business and economic dependence on them.
Applicable Law
• 1987 Philippine Constitution, Article XIII, Section 3 (security of tenure)
• Labor Code, Article 4 (liberal construction in favor of labor)
• Rule 51, Section 8, Rules of Court (scope of issues on appeal)
• 2005 NLRC Revised Rules, Rule VI, Section 6 (appeal bond requirement and reduction)
• Jurisprudence on employer–employee tests (ViaAa v. Al-Lagadan; Francisco v. NLRC)
Supreme Court Ruling
...continue readingCase Syllabus (G.R. No. 203023)
Facts
- Petitioners Richard N. Wahing, Ronald L. Calago, and Pablo P. Mait (“Wahing et al.”) worked as rubber tree tappers on the plantations of Spouses Amador Daguio and Esing Daguio (“the Daguio Spouses”).
- Mait was first ordered to “stop tapping the rubber tree” on October 15, 2006; Wahing and Calago received similar orders on February 6, 2007.
- Wahing et al. filed a complaint for illegal dismissal, reinstatement or separation pay, underpayment of wages, labor-standards benefits, damages, and attorney’s fees.
- The Labor Arbiter dismissed the complaint, characterizing the relationship as landlord-tenant rather than employer-employee.
- The National Labor Relations Commission (NLRC) set aside the Labor Arbiter’s dismissal and remanded the case for reception of evidence.
- On remand, only Wahing et al. filed position papers; the Labor Arbiter found illegal dismissal and awarded P777,090.52.
- The Daguio Spouses appealed and secured a second remand from the NLRC for their evidence; instead of addressing procedural objections, the Court of Appeals (CoA) took up the merits and ruled there was no employer-employee relationship, dismissing the complaint.
- Wahing et al. filed a Petition for Review on Certiorari before the Supreme Court, contending procedural defects in the Daguio Spouses’ appeal and insisting on the Labor Arbiter’s final decision.
Procedural History
- Labor Arbiter: Complaint dismissed as landlord-tenant relationship.
- NLRC First Action: VACATED Labor Arbiter’s dismissal; REMANDED for merits.
- Labor Arbiter on Remand: Found illegal dismissal; awarded back wages and benefits.
- NLRC Second Action: SET ASIDE Labor Arbiter’s decision; REMANDED for Daguio Spouses’ evidence.
- Court of Appeals: REVERSED NLRC remand; DISMISSED Wahing et al.’s complaint on merits for lack of employer-employee relationship.
- Supreme Court: GRANTED Petition for Review on Certiorari; REVERSED CoA decision; REINSTATED Labor Arbiter’s findings.
Issues
- May the Court of Appeals validly decide issues not assigned as errors on appeal in order to achieve a just and compl