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Additional Labor Law Cases:

1. GR 113542 Feb 24, 1998 - Caurdanetaan Piece Workers Union v. Laguesma


2. GR 16275 Feb 23, 1961 - Pan American World Airways System vs. Pan American Employees Association




Caurdanetaan Piece
Workers Union v.
Laguesma
- This case consists of 2 consolidated cases.
- The first case is an appeal from the decision of Laguesma, as
Undersecretary of Labor, in the Petition for Certification
Election filed by petitioner-union.
- The Caurdenataan Piece Workers Union is composed of the
employees of Corfarm Grains, Inc. They work as cargadores
in the said company and were paid on a piece rate basis.
- The said union was organized when some of their benefits were
not given to them. Thus, they filed their petition for certification
election. The Med-Arbiter granted the petition but this decision
was reversed, on appeal, by Laguesma saying that there was no
employer-employee relationship existing.
- The second case involves a complaint for illegal dismissal against
Corfarm. This arose because those workers who joined the said
union were replaced with non-members.
- As to this case, the labor arbiter first ruled in favor of the
workers but subsequently, the NLRC reversed such ruling.
- W/n there was an employer-
employee relationship between the
cargadores and Corfarm.
- YES. To determine the existence of an employer-employee
relation, this Court has consistently applied the four-fold test.
- It is undeniable that petitioners members worked as cargadores for
private respondent. They loaded, unloaded and piled sacks of
palay from the warehouses to the cargo trucks and from the cargo
trucks to the buyers. This work is directly related, necessary and
vital to the operations of Corfarm. Moreover, Corfarm did not
even allege, much less prove, that petitioners members have
substantial capital or investment in the form of tools,
equipment, machineries, [and] work premises, among others.
Furthermore, said respondent did not contradict petitioners
allegation that it paid wages directly to these workers without the
intervention of any third-party independent contractor. It also
wielded the power of dismissal over petitioners; in fact, its
exercise of this power was the progenitor of the Second Case.
Clearly, the workers are not independent contractors.
- It does not matter that the workers also work for other
companies because this is just their way of coping with their daily
expenses.
- No particular form of proof is required to prove the existence of
an employer-employee relationship. Any competent and relevant
evidence may show the relationship. If only documentary
evidence would be required to demonstrate that relationship, no
scheming employer would ever be brought before the bar of
justice.

2.Pan American World Airways System vs. Pan American Employees Association

FACTS:
Petitioner herein claims that the one hour meal period should not be considered as overtime work, because the evidence showed that complainants could rest completely, and
were not in any manner under the control of the company during that period. The court below found, on the contrary, that during the so-called meal period, the mechanics were
required to stand by for emergency work; that if they happened not to be available when called, they were reprimanded by the lead man; that as in fact it happened on many
occasions, the mechanics had been called from their meals or told to hurry up eating to perform work during this period.

ISSUE:
Whether or not the 1 hour meal period of the mechanics is considered working time.

HELD:
Yes. The Industrial Courts order for permanent adoption of a straight 8-hour shift including the meal period was but a consequence of its finding that the meal hour was not one of
complete rest but was actually a work hour, since for its duration, the laborers had to be on ready call.