1 GSIS Family Bank Employees Union v. Villanueva, G.R. No.
210773, 23 January 2019
Facts: Royal Savings Bank was organized as a private thrift bank and later renamed Comsavings
Bank. The Government Service Insurance System (GSIS) acquired a majority (99.55%) of Comsavings
Bank's outstanding shares, leading to its renaming as GSIS Family Bank. The Governance Commission
for GOCCs, created under Republic Act No. 10149, advised GSIS Family Bank that it was unauthorized
to enter into a CBA with its employees regarding economic terms. GSIS Family Bank refused to
negotiate a new CBA, citing the Governance Commission's opinion. The Bangko Sentral ng Pilipinas
Monetary Board prohibited GSIS Family Bank from doing business and designated the Philippine
Deposit and Insurance Corporation as its receiver.
Issue: W/N petitioner can enter into a CBA with its employees regarding economic terms
Held: The Supreme Court denied the petition, ruling that GSIS Family Bank, as a non-chartered
government-owned or controlled corporation (GOCC), could not enter into a collective bargaining
agreement (CBA) with its employees regarding economic terms due to Republic Act No. 10149 and
Executive Order No. 203, which established a Compensation and Position Classification System
applicable to all GOCCs. The Court also found that the petition for certiorari was not the correct
remedy and that the closure of GSIS Family Bank rendered the petition moot.
2 Philippine National Construction Corp. v. National Labor Relations Commission,
G.R. No. 248401, 23 June 2021
Facts: This is an appeal from a decision of the Court of Industrial Relations holding that the "parers"
and "shellers" of the petitioner, Sunripe Coconut Products Co., Inc., are its laborers entitled to
twelve days sick leave (one day for each month of service), notwithstanding the fact that they are
piece-workers under the "pakiao" system. The contention of the petitioner is that said "parers" and
"shellers" are independent contractors and do not fall within the category of employees or laborers.
The Court of Industrial Relations has relied upon the rule laid down in the case of Philadelphia
Record Company, 69 N.L.R.B., 1232 (1946), to the effect that when a worker possesses some
attributes of an employee and others of an independent contractor, which make him fall within an
intermediate area, he may be classified under the category of an employee when the economic facts
of the relation make it more nearly one of employment than one of independent business enterprise
with respect to the ends sought to be accomplished. Counsel for the petitioner does not dispute the
correctness or applicability of the rule, but it is vigorously contended that, in the case at bar, the
economic facts characteristic of the independent contractor far outweigh the economic facts
indicative of an employee.
Issue: W/N parers and shellers are independent contractors
Held: Yes. It is unnecessary to discuss at length the other facts pointed out by the petitioner in
support of the proposition that said "parers" and "shellers" are independent contractors, because a
ruling on the matter would necessarily involve a factual inquiry which we are not authorized to
make. Even so, we would undertake to advance the general remark that in cases of this kind,
wherein laborers are usually compelled to work under conditions and terms dictated by the
employer, a reasonably wide latitude of action and judgment should be given to the Court of
Industrial Relations with a view to settling industrial disputes conformably to the intents and
purposes of its organic law. Without in the least intimating that the relation between the "parers"
and "shellers" on the one hand and the petitioner on the other, as planned out by the latter, was
conceived knowingly to deprive said workers of the benefits accruing to workers who are admittedly
employees or laborers under Commonwealth Act No. 103 or the Workmen's Compensation Law, it is
not difficult to surmise that a contrary decision is likely to set a precedent that may tend to
encourage the adoption of a similar scheme by many other or even all employers.
3 Sunripe Coconut Products Co., Inc. v. Court of Industrial Relations, G.R. No. L-2009
(30 April 1949), 83 Phil 518-526)
Facts: This is an appeal from a decision of the Court of Industrial Relations holding that the "parers"
and "shellers" of the petitioner, Sunripe Coconut Products Co., Inc., are its laborers entitled to
twelve days sick leave (one day for each month of service), notwithstanding the fact that they are
piece-workers under the "pakiao" system. The contention of the petitioner is that said "parers" and
"shellers" are independent contractors and do not fall within the category of employees or laborers.
The Court of Industrial Relations has relied upon the rule laid down in the case of Philadelphia
Record Company, 69 N.L.R.B., 1232 (1946), to the effect that when a worker possesses some
attributes of an employee and others of an independent contractor, which make him fall within an
intermediate area, he may be classified under the category of an employee when the economic facts
of the relation make it more nearly one of employment than one of independent business enterprise
with respect to the ends sought to be accomplished. Counsel for the petitioner does not dispute the
correctness or applicability of the rule, but it is vigorously contended that, in the case at bar, the
economic facts characteristic of the independent contractor far outweigh the economic facts
indicative of an employee.
Issue: W/N parers and shellers are independent contractors
Held: Yes. It is unnecessary to discuss at length the other facts pointed out by the petitioner in
support of the proposition that said "parers" and "shellers" are independent contractors, because a
ruling on the matter would necessarily involve a factual inquiry which we are not authorized to
make. Even so, we would undertake to advance the general remark that in cases of this kind,
wherein laborers are usually compelled to work under conditions and terms dictated by the
employer, a reasonably wide latitude of action and judgment should be given to the Court of
Industrial Relations with a view to settling industrial disputes conformably to the intents and
purposes of its organic law. Without in the least intimating that the relation between the "parers"
and "shellers" on the one hand and the petitioner on the other, as planned out by the latter, was
conceived knowingly to deprive said workers of the benefits accruing to workers who are admittedly
employees or laborers under Commonwealth Act No. 103 or the Workmen's Compensation Law, it is
not difficult to surmise that a contrary decision is likely to set a precedent that may tend to
encourage the adoption of a similar scheme by many other or even all employers.
