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ANGEL JARDIN v. NLRC

FACTS:

Petitioners were drivers for respondent Philjama International Inc., operating under the "Goodman Taxi" brand. They worked on a 24-hour work schedule every other day and earned an average of P400.00 daily. However, respondent deducted P30.00 from their daily earnings for taxi unit washing, which petitioners believed to be illegal. In response, petitioners formed a labor union to protect their rights.

When respondent learned about the union formation, they refused to let petitioners drive the taxicabs starting from August 6, 1991. Petitioners suspected this was because they were the leaders and active members of the proposed union. In response, petitioners filed a complaint against respondent for unfair labor practice, illegal dismissal, and illegal deduction of washing fees.

The labor arbiter dismissed the complaint for lack of merit, but on appeal, the NLRC reversed and set aside the decision. The NLRC declared that petitioners were employees and ordered respondent to reinstate them to their former positions, pay full backwages and benefits, and reimburse the drivers for the washing charges. Respondent filed a motion for reconsideration, which was initially denied but later granted by the NLRC. The NLRC ruled that it had no jurisdiction over the case and dismissed the complaint for lack of jurisdiction. Petitioners sought reconsideration, but it was denied, prompting them to file a certiorari petition.

ISSUES:

  1. Whether or not the NLRC acted without or in excess of jurisdiction or with grave abuse of discretion in entertaining and granting a second motion for reconsideration filed by the private respondent.

  2. Whether or not an employer-employee relationship exists between the petitioners and the private respondent.

  3. Whether or not the petitioners were illegally dismissed.

RULING:

  1. Jurisdiction and Grave Abuse of Discretion: The Supreme Court ruled that the NLRC acted with grave abuse of discretion in taking cognizance and granting the private respondent's second motion for reconsideration. Rule 7, Section 14 of the NLRC New Rules of Procedure states that only one motion for reconsideration shall be entertained from the same party. Therefore, the NLRC should have denied the second motion for reconsideration outright.

  2. Employer-Employee Relationship: The Supreme Court held that an employer-employee relationship exists between the petitioners (taxi drivers) and the private respondent (Philjama International, Inc.). The Court rejected the NLRC’s view that the relationship was that of lessor-lessee, clarifying that under the boundary system, a control test indicates an employer-employee relationship. The private respondent exercises control over the petitioners' activities, justifying that the petitioners are employees.

  3. Illegal Dismissal: The Supreme Court concluded that the petitioners were illegally dismissed. The private respondent did not have a valid cause for termination, nor did it comply with the procedural requirements of notice and hearing as mandated by law. Thus, the petitioners are entitled to reinstatement and payment of full back wages from the time of their unlawful dismissal to their actual reinstatement, excluding reimbursement for washing charges.

PRINCIPLES:

  • Grave Abuse of Discretion: Acts that exceed jurisdiction or disregard applicable rules and procedures are considered grave abuse of discretion.

  • Employer-Employee Relationship: The control test is paramount in determining an employer-employee relationship, focusing on the right to control not just the end result but also the means and methods of accomplishing the work.

  • Illegal Dismissal: Dismissals must be based on just or authorized causes and must comply with the procedural requirements of notice and hearing.

  • Back Wages: Employees unjustly dismissed are entitled to full back wages from the time compensation was withheld up to actual reinstatement, especially for dismissals occurring post-March 21, 1989, under Republic Act No. 6715.