GR 121327; (December, 2001) (Digest)
G.R. No. 121327; December 20, 2001
CECILIO P. DE LOS SANTOS and BUKLOD MANGGAGAAGA NG CAMARA (BUMACA), petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION (SECOND DIVISION), HON. COMMISSIONERS VICTORIANO R. CALAYCAY, RAUL T. AQUINO, and ROGELIO I. RAYALA, CAMARA STEEL INDUSTRIES INC., JOSELITO JACINTO, ALBERTO F. DEL PILAR, DENNIS ALBANO, MERCEDITA G. PASTRANA, TOP-FLITE and RAUL RUIZ, respondents.
FACTS
Petitioner Cecilio P. de los Santos was employed by Camara Steel Industries Inc. (Camara Steel). On May 11, 1993, while performing janitorial duties, he was instructed by a supervisor to transfer a box declared as scrap. A security guard discovered electric cables inside the box. Although the supervisor admitted fault, Camara Steel later filed a criminal complaint for frustrated qualified theft against de los Santos, which was dismissed by the prosecutor. On August 23, 1993, upon request of Top-Flite, a purported manpower agency, Camara Steel terminated de los Santos’s services.
De los Santos filed an illegal dismissal case. The Labor Arbiter ruled in his favor, ordering reinstatement with full back wages, finding Camara Steel as his real employer. On appeal, the NLRC reversed and remanded the case to the Labor Arbiter, citing the need to determine the existence of an employer-employee relationship and to summon Top-Flite as a necessary party, noting a lack of independent evidence from de los Santos.
ISSUE
Whether the NLRC committed grave abuse of discretion in remanding the case to the Labor Arbiter for further proceedings on the employer-employee relationship and for failure to summon Top-Flite.
RULING
Yes. The Supreme Court granted the petition, reversing the NLRC and reinstating the Labor Arbiter’s decision. The legal logic is twofold. First, on the substantive issue, the Court found that de los Santos had sufficiently established his status as a regular employee of Camara Steel, not a contractual worker of Top-Flite. The evidence on record, which the NLRC erroneously disregarded, included his appointment papers, payroll documents, and identification cards from Camara Steel, all indicating direct employment and control by the company.
Second, on the procedural issue, the NLRC’s remand for failure to summon Top-Flite was unjustified. The records clearly showed that Top-Flite was impleaded as a respondent and had voluntarily participated by submitting a position paper before the Labor Arbiter. Jurisdiction over a party can be acquired by voluntary appearance, which includes the submission of pleadings. A remand would only cause undue delay and hardship to the worker, contravening the principle that technical rules are relaxed in labor cases to serve substantive justice. The NLRC’s decision constituted a grave abuse of discretion for being contrary to the evidence and established procedure.