EMMANUEL D. QUINTANAR v. COCA-COLA BOTTLERS

FACTS:

The complainants in this case are former employees of Coca-Cola Bottlers Philippines, Inc. (Coca-Cola) who were assigned as regular Route Helpers under the direct supervision of Route Sales Supervisors. They were responsible for distributing Coca-Cola products and were hired from 1984 to 2000. Throughout their employment, they were transferred to various manpower agencies. The complainants alleged that the Department of Labor and Employment (DOLE) declared them regular employees and held Coca-Cola liable for underpayment of their benefits. After filing their claims, they were dismissed by Coca-Cola in 2004. The complainants then filed a complaint for illegal dismissal in 2006. They argued that they were regular employees based on a Supreme Court decision in another case. Coca-Cola denied an employer-employee relationship with them and asserted that Interserve, a service contractor, was their employer. The case involves a group of employees who were formerly employed by Coca-Cola and were transferred to various service contractors including Interserve. The employees filed a complaint and sought reinstatement and payment of backwages. The Labor Arbiter ruled in favor of the employees, as did the National Labor Relations Commission. However, the Court of Appeals reversed the rulings, stating that the employees were not employees of Coca-Cola but of Interserve, based on their contracts of employment and personal data sheets. The Court of Appeals considered various factors in reaching this conclusion, including the payment of salaries by Interserve and the control exercised by Interserve over the employees. The employees sought reconsideration but were denied, prompting them to file a petition for review on certiorari, arguing that the Court of Appeals erred in reassessing the evidence and violating the doctrine of stare decisis. They also claimed that Interserve was a labor-only contractor and that both Interserve and Coca-Cola should be held liable for their claims.

ISSUES:

  1. Whether the petitioners were illegally dismissed from their employment with Coca-Cola.

  2. Whether ISI, Lipercon, PSI, ROMAC, and Interserve are labor-only contractors, making Coca-Cola liable for the petitioners' claims.

  3. Whether the work assigned to the respondent workers is necessary or desirable in the usual business or trade of the petitioner company.

  4. Whether the repeated rehiring and continuing need for the services of the respondent workers indicate the necessity or desirability of their services.

  5. Whether the fixed-term employment contract of the respondent workers is valid and legal.

  6. Whether Interserve is an independent job contractor.

  7. Whether there is an employer-employee relationship between Coca-Cola and the route-helpers.

  8. Whether the doctrine of stare decisis should be applied in this case.

  9. Whether the petitioners are regular employees of Coca-Cola or Interserve.

  10. Whether the petitioners were victims of labor-only contracting

  11. Whether Coca-Cola successfully rebutted the allegation that the petitioners were transferred to labor-only contractors

  12. Whether Coca-Cola proved that the petitioners voluntarily resigned from their employment

    • Whether or not the Labor Arbiter's decision in NLRC Case Nos. 12-13956-07 and 12-14277-07 should be reinstated.

RULING:

  1. The Court finds for the petitioners. With regards to the first issue, the Court notes that the petitioners have raised questions of fact, which are within the jurisdiction of the NLRC to resolve. However, due to conflicting findings from the labor tribunals, the Court is compelled to resolve the factual issues along with the legal ones. As for the second issue, the Court rules that route-helpers, such as the petitioners, still maintain an employee-employer relationship with Coca-Cola even after becoming employees of Interserve. The Court cites a previous case to support this ruling.

  2. The work assigned to the respondent workers is necessary or desirable in the usual business or trade of the petitioner company. The nature of the work performed must be viewed from the perspective of the business or trade in its entirety.

  3. The repeated rehiring and continuing need for the services of the respondent workers indicate the necessity or desirability of their services. The fact that respondent workers have been engaged for at least one year and the nature of their work demonstrate the regular conduct of the business or trade of the petitioner company.

  4. The fixed-term employment contract of the respondent workers is invalid and illegal. It is apparent that the fixed-term employment was imposed to preclude the acquisition of tenurial security by the employees, which is contrary to law, morals, good customs, public order, and public policy.

  5. Interserve is not an independent job contractor. The court found that Interserve did not have substantial capital or investment in the form of tools, equipment, machineries, and work premises. The service vehicles and equipment of Interserve were insufficient to carry out its service contract with Coca-Cola. Thus, Interserve falls under the definition of a labor-only contractor under the Labor Code.

  6. There is an employer-employee relationship between Coca-Cola and the route-helpers. The contract of service between Coca-Cola and Interserve showed that Coca-Cola exercised control over the complainants. Therefore, Coca-Cola should be held liable for the complainants' claims.

  7. The doctrine of stare decisis should be applied in this case. Coca-Cola failed to show any strong and compelling reason to set aside the doctrine. It did not successfully demonstrate how the lower courts committed grave abuse of discretion in considering the petitioners as regular employees of Coca-Cola and not of Interserve.

  8. The petitioners are regular employees of Coca-Cola. The service agreements entered into between Coca-Cola and Interserve were made after the petitioners were hired by Coca-Cola and after they filed their complaint for illegal dismissal. The petitioners' bio-data sheets and their own testimonies confirm that they were directly hired by Coca-Cola and have been working for the company for several years. Their payslips, tax records, and employee identification cards also support their claim of being employees of Coca-Cola.

  9. The petitioners were victims of labor-only contracting. The Court found that the petitioners were performing activities directly related to the principal business of Coca-Cola, which is one of the indicators of labor-only contracting. It was also established that Interserve, the alleged contractor, did not have substantial capital or investment.

  10. Coca-Cola failed to rebut the allegation that the petitioners were transferred to labor-only contractors. The burden of proof lies with Coca-Cola, and they were unable to provide convincing evidence that the labor-only contractors were legitimate job contractors.

  11. Coca-Cola did not prove that the petitioners voluntarily resigned from their employment. The Court found it inconceivable that the petitioners would leave a stable job at Coca-Cola to become agency workers. Coca-Cola failed to provide evidence to support their claim.

    • The Labor Arbiter's decision in NLRC Case Nos. 12-13956-07 and 12-14277-07 is hereby reinstated.

PRINCIPLES:

  • The Court is not a trier of facts and only reviews errors of law in petitions for review on certiorari.

  • The Court may review and resolve factual issues when there is insufficient or insubstantial evidence, conflicting findings from lower courts, or too much conclusion or inference from the facts presented.

  • An employment should be considered regular if the employee has been engaged to perform activities that are usually necessary or desirable in the usual business or trade of the employer, regardless of the written or oral agreement between the parties.

  • The work undertaken by an employee must be necessary or desirable in the usual business or trade of the employer.

  • The nature of the work performed must be viewed from the perspective of the business or trade in its entirety and not on a confined scope.

  • The repeated rehiring and continuing need for the services of an employee indicate the necessity or desirability of their services.

  • Fixed-term employment contracts that are imposed to preclude the acquisition of tenurial security by employees are invalid and illegal.

  • Contracts of employment are impressed with public interest, and parties are not at liberty to insulate themselves from the impact of labor laws and regulations.

  • The doctrine of stare decisis requires courts to adhere to precedents and apply established principles of law to future cases with substantially similar facts.

  • Stare decisis ensures certainty and stability in the legal system and promotes consistency in judicial decisions.

  • Like cases should be decided alike, and once a question of law has been examined and decided, it should be considered settled and closed to further argument.

  • The doctrine of stare decisis is based on the principle that absent powerful countervailing considerations, similar cases should be decided in the same manner.

  • Stare decisis is a bar to relitigating the same issue. It is a doctrine of importance in the judicial system and should only be set aside if strong and compelling reasons exist to do so.

  • In determining employer-employee relationship, the most important factor is the control exercised by the alleged employer. Other factors to consider include the nature of the work, the length of service, and the payment of salaries.

  • Documentary evidence, such as bio-data sheets, payslips, tax records, and employee identification cards, can be used to establish employment relationship.

  • Affidavits without sufficient basis or personal knowledge may not carry evidentiary weight.

  • Labor-only contracting exists when the person supplying workers to an employer does not have substantial capital or investment and the workers are performing activities directly related to the principal business of the employer.

  • The burden of proof in illegal dismissal cases lies with the employer to show that the termination of employees is for a just and valid cause.

  • The scales of justice must be tilted in favor of the employee when doubts exist over the evidence presented by the parties.

  • The control test is used to determine the existence of an employer-employee relationship, but other circumstances must also be considered.