SALLY MIGUEL ET.AL., petitioner versus JCT GROUP INC.

and VICENTE CUEVAS,

respondent
[G.R. No. 157752. March 16, 2005]

FACTS:

Glorious Sun Garment Mfg. Co., a garment exporter folded up in October 1994 and its
manufacturing plant, facilities and equipment was taken over by De Soleil and American
Inter-Fashion Corp (AIFC), and absorbed its employees including the
petitioners.Following the EDSA Revolution, the PCGG sequestered De Soleil and AIFC and
took over their assets and operation. Later JCT Group and De Soleil executed
Management and Operating Agreement for the period of one year, renewable yearly at Commented [f1]:
the option of JCT. This is for the purpose of servicing De Soleil export quota to ensure its
rehabilitation and preserve its viability and profitability. And upon its expiration JCT did
not renew the agreement resulting to the stoppage of the business operation of De Soleil
and termination of the employment of the petitioners. The petitioners filed a complaint
of illegal dismissal and payment of backwages and other monetary claims before the
NLRC against Del Soleil, AIFC, PCGG, Glorious Sun, JCT, Nemesio Co and Vicente Cuevas.
The cases were consolidated. JCT and Cuevas filed a Motion to Dismiss founded on lack
of jurisdiction over the subject matter of the action because of the absence of an
employer-employee relationship. Without resolving the motion, the Labor Arbiter
rendered a decision in favor of the petitioners. JCT with Cuevas and Glorious Sun filed a
separate motion for the reduction of the appeal bond which was denied. Respondents
elevated the matter to the Supreme Court via Petition for Certiorari which was likewise
denied and this time with finality. On the other hand Glorious Sun appealed the decision
of the LA to the NLRC. The petitioners filed a Motion to Dismiss for failure of the former
to post a bond as required by law. In response, the NLRC modified the LA’s decision
absolving Glorious Sun from liability and dismissing the respondents’ appeal. The
respondents instituted a special civil action for Certiorari before the SC which the latter
referred to the CA. The CA reversed the ruling of the NLRC and remanded the case to
the LA for further proceedings, hence the appeal.

ISSUE:

Whether or not the CA committed error in remanding the case to the LA?

RULING:

NO. The LA and NLRC committed grave abuse of discretion in ruling in favor of the
petitioners without determining the existence of an employer-employee relationship
between the petitioners and the respondents. The facts and the law on which decisions
are based must be clearly and distinctly expressed. The failure of the labor arbiter and
the NLRC to express the basis for their Decisions was an evasion of their constitutional
duty, an evasion that constituted grave abuse of discretion. The facts and the law on
which decisions are based must be clearly and distinctly expressed. The failure of the
labor arbiter and the NLRC to express the basis for their Decisions was an evasion of their
constitutional duty, an evasion that constituted grave abuse of discretion. Where a
judgment fails to make findings of fact, the case may be remanded to the lower tribunal
to enable it to determine them. Indeed, the only way to find out whether Respondents
JCT and Cuevas are liable to petitioners is by remanding the case to the lower court. To
uphold the Decisions of the labor arbiter and the NLRC at this stage would amount to
depriving respondents of property without due process. In sum, the CA did not commit
reversible error in finding grave abuse of discretion on the part of the NLRC and the labor
arbiter for their failure to state the facts upon which their conclusions had been based.
The petition is denied, and the assailed decision is affirmed.