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ARIEL L. DAVID v. JOHN G. MACASIO

FACTS:

In this case, John Macasio filed a complaint against Ariel David, doing business as "Yiels Hog Dealer," for non-payment of overtime pay, holiday pay, 13th month pay, and other monetary claims. Macasio worked as a butcher for David, who exercised control and supervision over his work. Macasio alleged that David determined his work day and reporting time, as well as the hogs to be chopped, and approved or disapproved his leaves. He claimed that David owned the hogs and work tools, and that David employed about twenty-five butchers and delivery drivers. On the other hand, David argued that Macasio was hired on a task basis and was not entitled to certain benefits.

The Labor Arbiter and the National Labor Relations Commission both dismissed Macasio's complaint, but the Court of Appeals (CA) partly granted his petition. The CA ruled that Macasio is entitled to his monetary claims as a task basis employee. However, the CA clarified that he is excluded from holiday, service incentive leave, and 13th month pay only if he is considered a "field personnel." Since Macasio worked as a butcher under David's supervision and control, the CA held that he is not considered a "field personnel" and is therefore entitled to the monetary claims.

In response, David filed a petition to reverse the CA's decision, arguing that Macasio was engaged on a task basis and should not be entitled to benefits. Macasio countered that he was not a task basis employee and that his engagement and payment indicated regular employment. He also argued that David's submissions raised factual issues not proper for a petition for review on certiorari. The issue in the case centers on the correct interpretation and application of labor law provisions on labor standards benefits to a worker engaged on a task basis.

ISSUES:

  1. Whether the Court of Appeals (CA) correctly found the National Labor Relations Commission (NLRC) in grave abuse of discretion when ruling on Macasio's entitlement to holiday pay, service incentive leave (SIL), and 13th month pay.

  2. Whether a worker engaged on a "pakyaw" or task basis qualifies for holiday pay, SIL, and 13th month pay under Philippine labor law provisions.

RULING:

  1. Grave Abuse of Discretion by NLRC: The Supreme Court found that the NLRC committed grave abuse of discretion in denying Macasio's claims for holiday and SIL pay simply because he is paid on a non-time basis without determining whether he is a field personnel.

  2. Entitlement to Holiday and SIL Pay: The Court upheld the CA’s decision that Macasio is entitled to holiday pay and SIL pay, as he does not fall under the classification of "field personnel" and is therefore not exempted from these benefits, despite being engaged on a "pakyaw" or task basis.

  3. Entitlement to 13th Month Pay: The Supreme Court held that Macasio is not entitled to 13th month pay, reversing the CA's decision on this aspect. The law exempts workers paid on a task basis from the coverage of 13th month pay without any reference to the "field personnel" requirement.

PRINCIPLES:

  1. Grave Abuse of Discretion: The NLRC can be found in grave abuse of discretion for not considering key factors such as whether an employee qualifies as "field personnel" when determining exemptions from labor benefits.

  2. Employment Relationship and Payment Method: An employment relationship can exist regardless of the payment method, such as "pakyaw" or task basis. Payment method alone does not negate an employment relationship.

  3. Four-Fold Test of Employment Relationship: This includes the selection and engagement of the employee, payment of wages, power of dismissal, and the power to control the employee’s conduct.

  4. Holiday and SIL Pay Coverage: Employees paid on a task basis are not automatically exempt from holiday and SIL pay unless they are also classified as "field personnel" who perform duties away from the principal place of business and whose actual hours of work cannot be determined with reasonable certainty.

  5. 13th Month Pay Exemption: Workers paid on a task basis are exempt from 13th month pay regardless of whether they are considered "field personnel".