G.R. No. 257821 , August 19, 2024
ROGELIO GARALDE MENDAROS, ROMEO DELA CRUZ, JR., JULIUS CAESAR GUTIERREZ, REY ABALOS, JEREMIAH MUGA, KING MICHAEL MUIT, AND JUNE SUAREZ, PETITIONERS, VS. LAZADA E-SERVICES PHIL., INC./ALLAN DAVID ANCHETA, RESPONDENTS.

FACTS

In April 2016, petitioners were hired by respondent Lazada E-Services Phil., Inc. (Lazada) as motorcycle riders under similarly worded Independent Contractor Agreements, effective for one year. The agreements stipulated that no employer-employee relationship existed. The agreements of Rogelio, Rey, Jeremiah, and Michael expired on April 1, 2017; Julius’s lapsed on April 6, 2017. June’s agreement was discontinued a few days before its term ended. Romeo’s agreement was prematurely terminated for allegedly violating Clause 6 by reproducing and using independent contractor identification cards. Petitioners filed a complaint for illegal dismissal, money claims, damages, and attorney’s fees before the Labor Arbiter (LA), asserting they were regular employees unjustly dismissed. Lazada contended the agreements were contracts for services, negating an employer-employee relationship and placing jurisdiction with the regular courts. The LA dismissed the complaint for lack of jurisdiction, a ruling affirmed by the National Labor Relations Commission (NLRC) and the Court of Appeals (CA). The CA debunked petitioners’ evidence, including Run Sheets, Independent Contractor Daily Time Logs, a Certificate of Employment, a Letter of Final Warning, an Identification Card, and Disbursement Vouchers, finding they did not establish Lazada’s control over the means and methods of their work.

ISSUE

Whether the CA committed reversible error in affirming the labor tribunals’ ruling that petitioners were independent contractors and not employees of Lazada, thereby negating an employer-employee relationship. Subsumed issues are: (1) whether petitioners’ tasks as riders were necessary or desirable in Lazada’s usual business; (2) whether petitioners satisfied the four-fold test of employment; and (3) whether petitioners were economically dependent on their work for Lazada.

RULING

The Supreme Court denied the petition. It held that no employer-employee relationship existed between petitioners and Lazada. The Court applied the four-fold test (selection and engagement, payment of wages, power of dismissal, and power of control) and emphasized control as the most important indicator. It found that the agreements clearly stipulated an independent contractor relationship, and petitioners failed to present substantial evidence to overcome this stipulation and prove Lazada’s control over the means and methods of their work. The evidence presented—Run Sheets, Daily Time Logs, a Certificate of Employment, a Letter of Final Warning, an Identification Card, and Disbursement Vouchers—did not demonstrate that Lazada controlled how petitioners performed their delivery services. The Court also noted that the tasks of riders were not necessary or desirable to Lazada’s usual trade or business as an e-commerce platform, citing precedent (Ditiangkin v. Lazada E-Services Philippines, Inc.). Furthermore, the economic dependence test was not satisfied, as petitioners were not prevented from seeking other sources of income. The termination of their contracts upon expiration did not constitute illegal dismissal, and jurisdiction properly lay with the regular courts.