Jardin v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners, taxi drivers for private respondent Philjama International Inc. (Goodman Taxi), operated under the boundary system, paying P30.00 daily for washing fees. Believing this deduction illegal, they planned to form a labor union. Upon learning of this, private respondent allegedly refused to let them drive their taxicabs starting August 6, 1991, leading petitioners to suspect they were singled out due to their union activities. Procedural History: Petitioners filed a complaint for unfair labor practice, illegal dismissal, and illegal deduction of washing fees. The Labor Arbiter dismissed the complaint. The NLRC, on appeal, reversed the Labor Arbiter, declaring petitioners employees and ordering their reinstatement with backwages and reimbursement of washing charges. Private respondent's first motion for reconsideration was denied. However, upon a second motion for reconsideration, the NLRC set aside its previous decision, ruling it lacked jurisdiction because the relationship was a leasehold under the Civil Code, not an employer-employee relationship under the Labor Code. Petitioners' motion for reconsideration of this latter decision was denied. The Petition: Petitioners filed a special civil action for certiorari, alleging that the NLRC acted without or in excess of jurisdiction, or with grave abuse of discretion, in entertaining the second motion for reconsideration and in reversing its earlier finding of an employer-employee relationship.
Issue(s)
Whether the NLRC committed grave abuse of discretion in entertaining and granting private respondent's second motion for reconsideration. Whether the employer-employee relationship between the parties was already a settled issue constituting res judicata. Whether petitioners, as taxi drivers under the boundary system, are employees of the private respondent; Whether their dismissal was illegal; and Whether the washing charges were illegal.
Ruling
The petition is granted. The assailed decision of the NLRC dated October 28, 1994, is set aside. The decision dated April 28, 1994, and the resolution dated December 13, 1994, are reinstated with modification. Private respondent is directed to reinstate petitioners, pay them full backwages from the date of dismissal until actual reinstatement, but the order for reimbursement of washing charges is deleted.
Ratio Decidendi
On the NLRC's grave abuse of discretion in entertaining the second motion for reconsideration: The Court held that the NLRC committed grave abuse of discretion amounting to lack or excess of jurisdiction by entertaining and granting the private respondent's second motion for reconsideration. This action violated Rule 7, Section 14 of the NLRC's New Rules of Procedure, which explicitly allows only one motion for reconsideration from the same party. The Court emphasized that disregarding its own rules, even in the name of "satisfying the ends of justice," is not permissible, especially when it leads to a disposition that runs counter to established jurisprudence. The rationale behind limiting motions for reconsideration is to ensure expeditious and inexpensive settlement of labor cases, preventing undue delays that can prejudice the livelihood of employees. The NLRC's act of entertaining a prohibited pleading undermined the orderly procedure for seeking reliefs in labor cases. On the issue of res judicata: While the Court found the NLRC's entertainment of the second motion for reconsideration to be grave abuse of discretion, it also addressed the substantive issue of the employer-employee relationship. The Court noted that the NLRC's initial decision had already declared an employer-employee relationship and ordered reinstatement, which implies that this issue was considered and decided. However, the primary basis for granting the petition was the NLRC's procedural error in allowing the second motion for reconsideration, which effectively allowed the reversal of a settled issue without proper legal basis. On the existence of an employer-employee relationship, illegal dismissal, and washing charges: The Court reiterated that the relationship between taxi owners/operators and taxi drivers under the boundary system is one of employer-employee, not lessor-lessee. Applying the four-fold test, particularly the control test, the Court found that taxi companies exercise supervision and control over drivers, dictating routes and operational rules, which is characteristic of an employer-employee relationship. The fact that drivers do not receive fixed wages but only the excess of the boundary paid is not sufficient to negate this relationship. The Court applied by analogy established jurisprudence concerning jeepney, bus, and auto-calesa operators and drivers. Therefore, petitioners, as taxi drivers, performed activities necessary and desirable in the usual business of the private respondent, establishing them as employees. Since the petitioners were found to be employees, their dismissal must be for a just or authorized cause and must comply with the twin-notice requirement. The Court found that the private respondent had no valid cause for termination and failed to provide the required notices, thus rendering the dismissal illegal. Consequently, petitioners are entitled to reinstatement without loss of seniority and full backwages, computed from the time their compensation was withheld until actual reinstatement, as their dismissal occurred after the effectivity of Republic Act No. 6715. The Court ruled that the P30.00 daily deduction for washing charges was not illegal. It reasoned that it is incumbent upon the driver to restore the taxi unit to the same clean condition as when taken out, and car washing after a tour of duty is a common practice in the taxi industry dictated by fair play. Therefore, drivers are not entitled to reimbursement of these charges.
Main Doctrine
The NLRC committed grave abuse of discretion in entertaining a second motion for reconsideration, which is a prohibited pleading under its own rules. Furthermore, taxi drivers operating under the boundary system are considered employees, not lessees, of the taxi company, as the company exercises sufficient control over their conduct and the management of the business.