Benigno Vigilla, et al. v Philippine College of Criminology, Inc. GR No.

200094, June 10,

2013
Facts:
The petitioners work for the Philippine College of Criminology Inc. (PCCr) as janitors, janitress
and supervisor in its maintenance department. The petitioners were made to understand by the
respondent PCCr that they are under the Metropolitan Building Services, Inc. (MBMSI) which is
a corporation engaged in providing janitorial services. PCCr terminated the services of MBMSI
on 2009 which resulted in the dismissal of the petitioners. An illegal dismissal complaint was
then filed against PCCr by the petitioners contending that it is their real employer and not
MBMSI. Subsequently, the PCCr submitted to the Labor Arbiter waivers, releases and
quitclaims that were executed by the petitioners in favor to MBMSI.
The Labor Arbiter and NLRC ruled in favor of the petitioner, however upon filing the petition for
review on certiorari before the Court of Appeals, the CA ruled that the quitclaims, releases and
waivers executed by the petitioners in favor to MBMSI redounds to the benefit of PCCr by virtue
of solidary liability under Article 1217 of the NewCivil Code. The petitioners contend that under
Article 106 of the Labor Code a labor-only contractor's liability is not solidary as it is the
employer who should be directly responsible to the supplied worker.
Issue
Whether or not the quitclaims, releases and waivers executed by the petitioners in favor to
MBMSI redounds to the benefit of PCCr?
Held Yes.
The Supreme Court held that the basis of the solidary liability of the principal with those
engaged in labor-only contracting is the last paragraph of Article 106 of the Labor Code that
provides, "In such cases of labor-only contracting, the person or intermediary shall be
considered merely as an agent of the employer who shall be responsible to the workers in the
same manner and extent as if the latter were directly employed by him."

It also pointed out D.O. No. 18-A, s. 2011 section 27 providing for the effects of labor-only
contracting "where upon the finding by competent authority of labor-only contracting shall render
the principal jointly and severally liable with the contractor to the latter's employees, in the same
manner and extent that the principal is liable to employees directly hired by him/her, as provided
in Article 106 of the Labor Code."

Hence, the PCCr's solidary liability was already expunged by virtue of the releases, waivers and
quitclaims executed by the petitioners in favor of MBMSI by virtue of Article 1217 of the Civil
Code providing that "payment made by one of the solidary debtors extinguishes the
obligation."