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BENIGNO M. VIGILLA v. PHILIPPINE COLLEGE OF CRIMINOLOGY INC.

FACTS:

This case involves a petition for review on certiorari filed by the petitioners against several resolutions of the NLRC. The petitioners, who were janitors, janitresses, and a supervisor, were initially made to believe that they were employed by MBMSI. However, it was later discovered that MBMSI's Certificate of Incorporation had been revoked. In 2009, the petitioners filed complaints alleging that PCCr was their real employer and MBMSI was a labor-only contractor. PCCr argued that it was not the direct employer and presented releases, waivers, and quitclaims executed by the petitioners. The LA ruled in favor of the petitioners, declaring PCCr as their real principal employer. The NLRC affirmed the LA's findings, but held that the releases, waivers, and quitclaims extinguished the respondents' liability.

In a separate case, the petitioners, who were former security guards, filed a complaint against PCCr, MBMSI, and Atty. Seril for underpayment of wages and non-payment of benefits. The LA ruled in favor of the petitioners and held MBMSI and Atty. Seril solidarily liable with PCCr. The NLRC modified the LA's decision, absolving MBMSI and Atty. Seril from liability due to the releases, waivers, and quitclaims executed by the petitioners. The petitioners denied signing the said documents and questioned the NLRC's declaration of MBMSI and Atty. Seril's liability. The NLRC modified its resolution, affirming the LA's decision only with respect to two complainants.

The 17 complainants filed a petition for certiorari before the CA, challenging the NLRC's decision. The CA denied the petition and upheld the authenticity and due execution of the releases, waivers, and quitclaims, as the petitioners failed to prove forgery. The petitioners then filed a petition for review before the Supreme Court, questioning the CA decision. The petitioners argued that the releases, waivers, and quitclaims were forged, but failed to provide concrete evidence. It was also confirmed that the petitioners were paid their separation pay and had executed the said documents. Since the petitioners were unable to provide copies of the alleged forged documents, their petition is subject to dismissal.

ISSUES:

  1. Whether the releases, waivers, and quitclaims executed by the employees were duly notarized and therefore valid.

  2. Whether the employees have provided concrete proof to substantiate their claim of forgery.

  3. Whether the revocation of MBMSI's Certificate of Incorporation absolves it from its liabilities.

  4. Whether there is solidary liability between the labor-only contractor and the employer.

  5. Whether the releases, waivers, and quitclaims in favor of the labor-only contractor, MBMSI, will redound to the benefit of the employer, PCCr.

  6. Whether there exists an employer-employee relationship between the principal employer and the employees of the labor-only contractor.

  7. Whether the principal employer is solidarily liable with the labor-only contractor for the rightful claims of the employees.

  8. Whether the releases, waivers, and quitclaims executed by the employees in favor of the labor-only contractor extinguished the liability of the principal employer.

  9. Whether every labor dispute should be automatically decided in favor of labor.

  10. Whether management also has rights that are entitled to respect and enforcement.

RULING:

  1. The releases, waivers, and quitclaims executed by the employees were duly notarized and therefore valid. The notarization gives prima facie evidence of their due execution.

  2. The employees failed to substantiate their claim of forgery. Their self-serving allegation was not supported by concrete proof.

  3. The revocation of MBMSI's Certificate of Incorporation does not absolve it from its liabilities. Even after the dissolution of the corporation, it is allowed a winding up period to settle and close its affairs, and its liabilities incurred prior to dissolution remain valid and binding.

  4. Yes, there is solidary liability between the labor-only contractor and the employer. The labor-only contractor's liability is deemed solidary with the employer, as stated in Article 106 of the Labor Code. The labor-only contractor is considered an agent of the employer, and the employer is responsible to the workers in the same manner and extent as if they were directly employed by the employer. This solidary liability is also recognized in Department Order No. 18-02 and Department Order No. 18-A, which interpret and implement the provisions of the Labor Code.

  5. The releases, waivers, and quitclaims in favor of the labor-only contractor, MBMSI, will redound to the benefit of the employer, PCCr. MBMSI is solidarily liable with the employer for the valid claims of the workers, as provided in Article 109 of the Labor Code. Therefore, the releases, waivers, and quitclaims issued to MBMSI will extinguish the liability of PCCr.

  6. The existence of an employer-employee relationship between the principal employer and the employees of the labor-only contractor is established by law. The purpose of this relationship is to ensure that the employees receive their wages.

  7. In the case of labor-only contracting, the principal employer is considered merely an agent of the labor-only contractor. The law imposes solidary liability on the principal employer and the labor-only contractor for the employees' rightful claims to prevent the circumvention of labor laws.

  8. The releases, waivers, and quitclaims executed by the employees in favor of the labor-only contractor extinguished the liability of the principal employer. This is in accordance with Article 1217 of the Civil Code, which states that payment made by one of the solidary debtors extinguishes the obligation.

  9. No, every labor dispute should not be automatically decided in favor of labor. While the Constitution is committed to the policy of social justice and the protection of the working class, justice must be dispensed in the light of the established facts and applicable law and doctrine.

  10. Yes, management also has rights that are entitled to respect and enforcement in the interest of fair play.

PRINCIPLES:

  • Notarization of a document gives prima facie evidence of its due execution.

  • Mere unsubstantiated allegations of forgery are not sufficient to overcome the presumption of authenticity and due execution of a duly notarized document.

  • Failure to comply with the requirements regarding the contents of and the documents accompanying a petition is a ground for dismissal of the appeal.

  • The revocation of a corporation's Certificate of Incorporation does not terminate its liabilities, and it is allowed a winding up period to settle and close its affairs.

  • The last paragraph of Article 106 of the Labor Code establishes solidary liability between the employer and labor-only contractor.

  • Department Order No. 18-02 and Department Order No. 18-A recognize and interpret the solidary liability of the employer and labor-only contractor.

  • Legislative rules and regulations designed to implement a primary legislation have the force and effect of law.

  • Jurisprudence supports the notion that a labor-only contractor is solidarily liable with the employer.

  • In legitimate job contracting, the principal employer becomes jointly and severally liable with the job contractor only for the payment of the employees' wages.

  • In labor-only contracting, the principal employer becomes solidarily liable with the labor-only contractor for the employees' rightful claims.

  • The Civil Code provisions on solidary liability, particularly Articles 1217 and 1222, are applicable to labor cases.

  • Releases, waivers, and quitclaims executed by employees in favor of a labor-only contractor can extinguish the liability of the principal employer.

  • The courts have a duty to protect the rights of employees and prevent their exploitation, but they also need to uphold the sanctity of contracts that do not contravene the law.

  • The Constitution is committed to the policy of social justice and the protection of the working class.

  • Every labor dispute should be decided in the light of the established facts and applicable law and doctrine.

  • Management also has rights that are entitled to respect and enforcement in the interest of fair play.