Facts:
1. In 1973, Sinclitica Candido was employed by Apex Mining Company, Inc., to perform laundry services at its staff house in Masara, Maco, Davao del Norte, initially paid on a piece rate basis.
2. On January 17, 1982, Candido’s pay scheme was changed to a monthly basis, starting at P250.00 and later increased to P575.00.
3. On December 18, 1987, Candido slipped while hanging laundry, injuring her back.
4. Candido reported the incident to her supervisor, Mila de la Rosa, and to the personnel officer, Florendo D. Asirit, and was allowed to take medical leave.
5. De la Rosa offered Candido P2,000, later increased to P5,000, to persuade her to resign, but Candido refused.
6. On February 4, 1988, she was dismissed from her job.
7. Candido filed for assistance with the Department of Labor and Employment on March 11, 1988.
8. The labor arbiter issued a decision on August 24, 1988, favoring Candido and ordering Apex Mining to pay her salary differential, emergency living allowance, 13th month pay differential, and separation pay totaling P55,161.42.
9. Apex Mining appealed to the National Labor Relations Commission (NLRC) which dismissed the appeal on July 20, 1989.
10. Apex Mining filed for a motion of reconsideration which was denied by the NLRC on June 29, 1990.
Issues:
1. Whether Sinclitica Candido should be classified as a domestic helper (househelper) or a regular employee of Apex Mining Company, Inc.
2. The legitimacy of Candido’s claim and her entitlement to the relief awarded by the labor arbiter.
Court’s Decision:
1. The Court ruled that Candido cannot be classified as a domestic helper under Rule XIII, Section 1(b), Book 3 of the Labor Code because her services were rendered in the staffhouses of the company for the benefit of the company’s guests and other personnel and not exclusively for the personal comfort and enjoyment of the employer’s family.
2. The Supreme Court declared that household helpers working in staff houses of a company are regular employees as they are performing services within the premises of the employer’s business. Therefore, Candido should be considered a regular employee of Apex Mining.
3. The Court affirmed the labor arbiter’s decision as upheld by the NLRC, categorically rejecting the argument that Candido abandoned her work. Evidence showed she was unable to perform her work due to an accident, leading to her separation from the service.
Doctrine:
-The term “househelper” as defined in the Labor Code refers exclusively to servants rendering services directly related to the personal comfort and enjoyment of the employer’s family within the employer’s home. It does not extend to employees performing similar roles within company premises or staffhouses.
-Employees working within the premises of the business, or in connection with its business, must be considered regular employees entitled to all statutory benefits.
Class Notes:
1. Househelpers vs. Regular Employees: Definition and scope per Rule XIII, Section 1(b), Book 3 of the Labor Code.
2. Employee Rights: The rights and benefits applicable to regular employees, including entitlement to salary differential, emergency living allowances, 13th month pay, and separation pay.
3. Illegal Dismissal: Grounds of consideration and the distinction of abandonment.
4. Evidence: Importance of evidence in proving the conditions of employment and entitlements.
Historical Background:
This case arose in the broader context of labor rights and protections in the Philippines, particularly concerning the classification and treatment of various types of workers. It underscores the distinction between domestic workers and employees providing services within business premises, reflecting the country’s ongoing efforts to refine labor laws and ensure fair treatment and necessary protections for all categories of employees.
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