Case Digest: Jardin vs. National Labor Relations Commission, G.R. No. 119268

 

Jardin vs. National Labor Relations Commission, G.R. No. 119268, February 23, 2000

Subject: Transportation Law

FACTS

Petitioners worked as drivers for Philjama International Inc., fulfilling responsibilities within a 24-hour work schedule under a boundary system. Notably, the private respondent consistently deducted P30.00 from the daily earnings of the petitioners, citing it as a fee for washing taxi units. Suspecting the legality of this deduction, the petitioners, in an effort to protect their rights and interests, formed a labor union. However, tensions arose when, on August 6, 1991, the private respondent, suspecting union formation, prohibited the petitioners from driving.

In response to this restriction, petitioners filed a comprehensive complaint, encompassing allegations of unfair labor practices, illegal dismissal, and illegal deduction. Despite their efforts, the labor arbiter dismissed the complaint for lack of merit. Subsequently, the National Labor Relations Commission (NLRC) intervened, reversing the labor arbiter's decision and officially recognizing the petitioners as employees.

While the private respondent's initial motion for reconsideration was denied, a subsequent attempt proved successful. This turn of events prompted the petitioners to seek reconsideration, alleging grave abuse of discretion in the proceedings.

ISSUE/S

1. Whether NLRC has jurisdiction to entertain the second motion for reconsideration.

2. Whether the existence of an employer-employee relationship is a settled issue.

3. Whether existing jurisprudence supports the view that petitioners are employees.

RULING

1. Yes, the court held that NLRC's acceptance of the second motion for reconsideration was a violation of its own rules, constituting grave abuse of discretion. NLRC's rules explicitly allow only one motion for reconsideration from the same party. The court emphasized the importance of adhering to procedural rules to ensure an expeditious resolution of labor cases. The court noted that the rationale for allowing only one motion for reconsideration is to promote the swift and cost-effective settlement of labor disputes.

2. Yes, the court disagreed with NLRC's ruling that there was no employer-employee relationship between the parties. It cited prevailing jurisprudence that establishes the relationship between taxi owners/operators and taxi drivers under the boundary system as that of employer-employee, not lessor-lessee. The court emphasized that control is a crucial factor in determining an employer-employee relationship, and the owners/operators did exercise supervision and control over the drivers.

3. Yes, the court reiterated that termination of employment must follow legal procedures and be based on just and authorized causes. Since the termination of petitioners was without valid cause and lacked compliance with notice and hearing requirements, it was deemed illegal. The court ordered private respondent to reinstate the petitioners to their positions and pay them full backwages, computed from the date of dismissal until their actual reinstatement.