GR L 75063; (June, 1988) (Digest)
G.R. Nos. 75063-64. June 30, 1988.
ELIZABETH ASIM, ET AL., petitioners, vs. HON. RICARDO C. CASTRO, ET AL., and CONTINENTAL CEMENT CORP., respondents.
FACTS
Petitioners filed complaints against Continental Cement Corporation (CONTINENTAL) and Celia Maningas for illegal dismissal and various monetary claims. The Labor Arbiter initially ruled in favor of petitioners, ordering their reinstatement and payment of benefits by CONTINENTAL. The NLRC affirmed but, on CONTINENTAL’s motion for reconsideration, remanded the case for further proceedings to allow CONTINENTAL and Maningas to present evidence. After rehearing, the Labor Arbiter found that petitioners were employees of Celia Maningas, an independent contractor, and not of CONTINENTAL. Consequently, Maningas was held solely liable for the monetary claims, while CONTINENTAL was absolved. The NLRC dismissed petitioners’ appeal, prompting this certiorari petition.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter’s finding that no employer-employee relationship existed between petitioners and CONTINENTAL, thereby absolving CONTINENTAL from liability for the claimed benefits.
RULING
The Supreme Court dismissed the petition, upholding the NLRC’s findings. The Court reiterated that the existence of an employer-employee relationship is a question of fact, and factual findings of the NLRC, when supported by substantial evidence, are accorded respect and finality. The Labor Arbiter’s findings, affirmed by the NLRC, were based on substantial evidence showing that Celia Maningas was an independent contractor and the direct employer of petitioners.
The evidence established that Maningas alone exercised the prerogatives of an employer: she selected and engaged the petitioners, fixed and paid their wages, and exercised control and supervision over their work. A service contract between CONTINENTAL and Maningas explicitly stated that workers assigned by the contractor were not employees of the company. Identification cards issued by CONTINENTAL were merely for plant entry purposes and did not establish an employment relationship. Furthermore, a memorandum of agreement between some petitioners and Maningas acknowledged her as their employer. Petitioners’ claim of being CONTINENTAL employees since 1977 was contradicted by their own complaint, which stated their employment began in September 1982, after the service contract was executed. Since no employer-employee link with CONTINENTAL was proven, the company could not be held liable for illegal dismissal or the monetary claims. The NLRC did not act with grave abuse of discretion.