Fleischer Company, Inc. vs. National Labor Relations Commission (NLRC), Ruamar, et. al.
355 SCRA 105, GR No. 121608, March 26, 2001
FACTS:
Petitioner, an agricultural plantation, hired private respondents as security guards in 1989 due to their being members of the Civilian Home Defense Force (CHDF). Respondent Ruamar, who was hired as a utility man, was terminated from service on February 23, 1990 while respondent security guards Dalit, Vivero and Dubal were all terminated on March 13, 1990. Respondents, then, filed a complaint for illegal dismissal before the Labor Arbiter Aponesto. They insisted that they were entitled to wage differentials on the ground that as security guards their wages should be based on the industrial rate and not on the agricultural rate. Petitioner rejected respondents’ money claims contending that they are agricultural workers and not underpaid, and that the company’s payroll showed that they were given their money claims.
The Labor Arbiter ruled that respondents were illegally dismissed from service and ordered petitioner to pay the respondents’ respective separation pay, all on the ground that petitioner failed to sufficiently establish the facts to warrant the dismissal of the respondents. He, however, declined to award respondents their backwages because petitioner was found to be in good faith when it offered to pay respondents their separation pay as indicated in their letters of dismissal. On appeal, the NLRC reversed the Labor Arbiter’s finding of illegal dismissal on the ground that the case us analogous to or one involving redundancy since rh respondents’ services were no longet needed when the latter cased to be members of the CHDF abd when duly licensed security guards were already hired. The payment of separation pays was likewise ordered by the NLRC but later modified the decision by deleting the monetary award in favor of respondent Dalit.
ISSUE:
Whether or not there existed an employer-employee relationship between the parties
COURT RULING:
The Supreme Court accorded great weight and respect to the findings of the NLRC that there exists an employer-employee relationship between the parties, and, therefore, affirmed the NLRC’s first decision as modified by the resolution also made by NLRC.
It is well-settled that the existence of an employer-employee relationship is essentially a factual question and the NLRC’s findings thereon are accorded great weight and espect and even finality when the same are supported by substantial violence.
A review in the Supreme Court concerning factual findings in labor cases is confined to determining allegations of lack of jurisdiction or grave abuse of discretion.
