GR 119268; (February, 2000) (Digest)
G.R. No. 119268 February 23, 2000
ANGEL JARDIN, et al., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and GOODMAN TAXI (PHILJAMA INTERNATIONAL, INC.), respondents.
FACTS
Petitioners were taxi drivers for respondent Philjama International Inc., operating under a 24-hour boundary system every other day. Private respondent regularly deducted P30.00 daily from their earnings for vehicle washing. When petitioners began forming a labor union, respondent refused to let them drive starting August 6, 1991. Petitioners filed a complaint for unfair labor practice, illegal dismissal, and illegal deduction.
The Labor Arbiter dismissed the complaint. On appeal, the NLRC reversed the Arbiter, declared an employer-employee relationship existed, and found illegal dismissal, ordering reinstatement, full backwages, and reimbursement of washing charges. Private respondent filed a motion for reconsideration, which was denied. It then filed a prohibited second motion for reconsideration. The NLRC granted this second motion, reversing its own decision and dismissing the complaint for lack of jurisdiction, ruling no employer-employee relationship existed but rather a civil lease contract.
ISSUE
Whether the NLRC committed grave abuse of discretion in entertaining and granting a prohibited second motion for reconsideration and in subsequently ruling it lacked jurisdiction over the case.
RULING
Yes. The Supreme Court granted the petition, finding grave abuse of discretion. The NLRC Rules explicitly prohibit the filing of a second motion for reconsideration. By entertaining and granting this prohibited pleading, the NLRC capriciously disregarded the rules it is bound to observe, which constitutes grave abuse of discretion amounting to lack or excess of jurisdiction. The Court cited precedents where labor tribunals were found to have gravely abused discretion for violating procedural rules.
On the substantive issue, the Court upheld the existence of an employer-employee relationship, applying the four-fold test. Private respondent exercised control over the drivers through rules on operation, appearance, and conduct. The boundary system does not preclude employment. Thus, the NLRC had jurisdiction. The Court reinstated the NLRC’s April 28, 1994 decision with modification: petitioners were illegally dismissed and entitled to reinstatement and full backwages without qualification or deduction. However, the daily washing fee deduction was deemed a lawful practice in the industry and not reimbursable.