Establishing Employer-Employee Relationship: The Importance of Evidence

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G.R. No. 118101, September 16, 1996, EDDIE DOMASIG, PETITIONER, VS. NATIONAL LABOR RELATIONS COMMISSION (SECOND DIVISION), CATA GARMENTS CORPORATION AND/OR OTTO ONG AND CATALINA CO, RESPONDENTS.

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Imagine being dismissed from your job and struggling to prove you were even an employee in the first place. This is the reality faced by many Filipino workers. Establishing a clear employer-employee relationship is crucial for claiming labor rights and benefits. In the case of Eddie Domasig v. National Labor Relations Commission, the Supreme Court clarified what constitutes sufficient evidence to prove this relationship, offering valuable guidance for both employees and employers.

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The Four-Fold Test and Employer-Employee Relationship

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Philippine labor law relies on the “four-fold test” to determine the existence of an employer-employee relationship. This test considers:

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• Selection and Engagement: How the employee was hired.

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• Payment of Wages: How the employee was compensated.

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• Power of Dismissal: The employer’s ability to terminate employment.

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• Power of Control: The employer’s control over the employee’s conduct.

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The most crucial element is often the employer’s power of control. This means the employer has the right to dictate not only what work should be done, but also how it should be done. The absence of a written contract does not automatically negate the existence of an employer-employee relationship. As the Court has repeatedly stated, it is the totality of circumstances that matters.

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Article 4 of the Labor Code states: “All doubts in the implementation and interpretation of the provisions of this Code, including its implementing rules and regulations, shall be resolved in favor of labor.” This provision underscores the pro-labor stance of Philippine law, emphasizing that ambiguities should be interpreted to benefit the employee.

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The Domasig Case: ID Cards, Vouchers, and Substantial Evidence

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Eddie Domasig claimed he was illegally dismissed by Cata Garments Corporation. The company denied he was a regular employee, arguing he was merely a commission agent. The Labor Arbiter ruled in Domasig’s favor, but the National Labor Relations Commission (NLRC) remanded the case for further proceedings, questioning the evidence of an employer-employee relationship. This prompted Domasig to elevate the matter to the Supreme Court.

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The Supreme Court focused on the evidence Domasig presented:

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• An identification card issued by Cata Garments Corporation.

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• Cash vouchers reflecting his monthly salaries.

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The Court emphasized that in administrative and quasi-judicial proceedings, such as labor cases,