Law School Noob: [CASE DIGEST] St. Martin Funeral Home v. NLRC and Bienvenido Aricayos

Thursday, September 26, 2013

[CASE DIGEST] St. Martin Funeral Home v. NLRC and Bienvenido Aricayos

September 16, 1998 | G.R. No. 130866

St. Martin Funeral Home, petitioner
National Labor Relations Commission and Bienvenido Aricayos, respondents

FACTS:

Bienvenido Aricayos worked as Operations Manager of St. Martin Funeral Home in San Fernando, Pampanga.

On January 22, 1996, he was dismissed from his employment for allegedly misappropriating P38,000.00 which was intended for payment by St. Martin Funeral Home of its value added tax (VAT) to the Bureau of Internal Revenue (BIR). Aricayos subsequently filed a complaint for illegal dismissal before the Labor Arbiter.

During the hearing, St. Martin Funeral alleged that Aricayos was not its employee. It was argued that there was employer-employee relationship because there was no contract of employment, nor was Aricayo's name included in the semi-monthly payroll. Further, St. Martin Funeral alleged that Aricayos was only helping the business and he was doing so voluntarily as an indication of gratitude for the financial assistance he had previously received from the owner of the business.

The Labor Arbiter ruled in favor of St. Martin Funeral and held that indeed, there was no employer-employee relationship between the parties.

But the Labor Arbiter's ruling was overturned by the NLRC, which ordered that the case be remanded back to the Labor Arbiter. Hence, the instant petition by St. Martin Funeral Home.

ISSUES:

1. Whether there was an employer-employee relationship between Aricayos and St. Martin Funeral Home. -- The SC did not discuss this issue.

2. Where should appeals of NLRC's decisions be filed? -- The Court of Appeals via petition for certiorari under Rule 65.

HELD:

1. The Court did not discuss the merits of the case. Instead, it reexamined the functional validity and systemic practicability of the mode of judicial review it has long adopted and still follows with respect to decisions of the NLRC. The increasing number of labor disputes that find their way to the Court and the legislative changes introduced over the years into the provisions of P.D. No. 442 (The Labor Code of the Philippines) and B.P. 129 (The Judiciary Reorganization Act of 1980) stridently call for and warrant a reassessment of that procedural aspect.

2. After reviewing statutory amendments to pertinent laws and the intent of the legislators, the Court declared that all references in the amended Section 9 of B.P. No. 129 (The Judiciary Reorganization Act of 1980) to supposed appeals from the NLRC to the Supreme Court are interpreted and hereby declared to mean and refer to petitions for certiorari under Rule 65. Consequently, all such petitions shall henceforth be initially filed in the Court of Appeals in strict observance of the doctrine on the hierarchy of courts as the appropriate forum for the relief desired.

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