Bautista vs.

Inciong

Case

G.R. No. 52824

Ponente

GUTIERREZ, JR., J

Decision Date

Mar 16, 1988

Reynaldo Bautista, an employee of the Associated Labor Unions (ALU), wins a case against ALU for illegal dismissal after the
Supreme Court rules that an employer-employee relationship exists between them, resulting in Bautista being awarded
backwages and separation pay instead of reinstatement due to the strained relationship between the parties.

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Facts:

 Reynaldo Bautista, an employee of the Associated Labor Unions (ALU), filed a complaint for illegal dismissal against
ALU.

 Bautista claimed that he was wrongfully terminated by ALU after being employed as an organizer since 1972.

 The National Capital Region Director of the Ministry of Labor (MOL) Region IV found in favor of Bautista, ordering
ALU to reinstate him with full backwages and other benefits.

 ALU appealed to the Ministry of Labor, and the respondent Deputy Minister dismissed Bautista's complaint, stating
that there was no employer-employee relationship between Bautista and ALU.

Issue:

 Whether an employer-employee relationship exists between Bautista and ALU.

Ruling:

 The Supreme Court ruled in favor of Bautista and held that an employer-employee relationship exists between him
and ALU.

 The Court found that the elements of an employer-employee relationship were present, including the selection and
engagement of the employee, payment of wages, power of dismissal, and the employer's power to control the
employee's work.

 The Court emphasized that the control test is the most important element in determining an employer-employee
relationship.

 The Court also noted that ALU's act of filing a clearance application to terminate Bautista's services further supports
the existence of an employer-employee relationship.

Ratio:

 The Court explained that the mere fact that ALU is a labor union does not exempt it from being considered an
employer.

 The Court outlined the factors in determining an employer-employee relationship, including the control test.
  In this case, the Court found that ALU had control over Bautista's work as one of its organizers, and there was no
factual or legal basis for the Deputy Minister's decision that there was no employer-employee relationship.

 However, due to the antipathy and antagonism between Bautista and ALU, the Court ruled that reinstatement was
not possible, and instead ordered ALU to pay Bautista backwages for three years and any separation pay he may be
entitled to.

 The Court cited previous cases where backwages were awarded as an alternative to reinstatement in situations
where reinstatement is no longer feasible.

SUMMARY

Case Background and Parties Involved

 The case of Bautista v. Inciong involves Reynaldo Bautista and the Associated Labor Unions (ALU).

 Bautista, an employee of ALU, was wrongfully dismissed and sought legal action.

 The case aims to establish Bautista's employment status and claim his entitled benefits.

Factors in Determining an Employer-Employee Relationship

 The Supreme Court emphasizes several factors in determining an employer-employee relationship.

 These factors include the selection and engagement of the employee, payment of wages, power of dismissal, and
the employer's control over the employee's work.

 The "control test" is the most crucial element, examining the extent of the employer's control over the employee's
work.

Regional Director's Findings

 The Regional Director of the Ministry of Labor (MOL) Region IV found that Bautista was an employee of ALU.

 Evidence supporting this conclusion includes Bautista's inclusion in ALU's individual payroll sheets, his membership
with the Social Security System (SSS) under ALU's coverage, and ALU's filing of a clearance application to terminate
Bautista's services.

 ALU had the power to hire and dismiss Bautista and tightly controlled his work as one of its organizers.

Deputy Minister's Dismissal and Argument

 The respondent Deputy Minister, Amado C. Inciong, dismissed Bautista's complaint.

 The Deputy Minister argued that no employer-employee relationship existed between Bautista and ALU.

 The Deputy Minister claimed that ALU, being a labor union, was not an employer and that the payments made to
SSS were merely favors for those engaged in full-time union activities.

Supreme Court's Disagreement and Ruling

 The Supreme Court disagreed with the Deputy Minister's decision, stating that there was no factual or legal basis for
his conclusion.

 The Court emphasized that being a labor union does not exempt ALU from being considered an employer.

 The evidence presented clearly demonstrated the existence of an employer-employee relationship between Bautista
and ALU.

 Due to the animosity between Bautista and ALU, the Court ruled that reinstatement was not feasible.
  Instead, the Court ordered ALU to pay Bautista backwages for three years and any separation pay he was entitled to
at the end of the three-year period.

Importance of Recognizing Employee Rights

 The case highlights the importance of recognizing and respecting the rights of employees, even within labor unions.

 It establishes the criteria for determining an employer-employee relationship.

 The case emphasizes the need for fair treatment and compensation for workers.