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Title	IDs & Reference #s	Background	Primary Holding	Subject Matter
Sasan, Sr. vs. National Labor Relations Commission 4th Division (17th October 2008)	AK941105 590 Phil. 685 , 569 SCRA 670 , G.R. No. 176240	E-PCIBank entered into a Contract for Services with HI, a company providing janitorial and messengerial services, which was renewed annually until 2001. When the contract finally expired, the bank bidded out its requirements to other agencies, leading to the pull-out of the petitioners from the bank's premises and their subsequent filing of illegal dismissal complaints.	Helpmate, Inc. is a legitimate independent job contractor because it possesses substantial capital and carries on a distinct business, meaning no employer-employee relationship exists between the principal bank and the contractor's employees; furthermore, the NLRC may validly consider evidence submitted for the first time on appeal to ascertain factual truths in labor cases.	Evidence
Ong Chia vs. Republic (27th March 2000)	AK747857 385 Phil. 487 , 328 SCRA 749 , G.R. No. 127240	Ong Chia arrived in the Philippines from China in 1932 at the age of nine and lived there for over five decades, establishing a business and a family. In 1989, he filed a petition for naturalization under C.A. No. 473, asserting he possessed all qualifications and no disqualifications. While the trial court was initially satisfied with his testimony and knowledge of Philippine history, the State later discovered discrepancies between his current petition and a previous 1977 administrative application for naturalization.	The rule on the formal offer of evidence under Rule 132, Section 34 of the Rules of Court does not strictly apply to naturalization proceedings; pursuant to Rule 143 (now Rule 1, Section 4), the Rules of Court apply only by analogy or in a suppletory character in such cases, allowing the appellate court to consider documents presented by the State for the first time on appeal to ensure the applicant's full qualification for citizenship.	Evidence

Title

IDs & Reference #s

Background

Primary Holding

Subject Matter

Sasan, Sr. vs. National Labor Relations Commission 4th Division

(17th October 2008)

AK941105

590 Phil. 685 , 569 SCRA 670 , G.R. No. 176240

E-PCIBank entered into a Contract for Services with HI, a company providing janitorial and messengerial services, which was renewed annually until 2001. When the contract finally expired, the bank bidded out its requirements to other agencies, leading to the pull-out of the petitioners from the bank's premises and their subsequent filing of illegal dismissal complaints.

Helpmate, Inc. is a legitimate independent job contractor because it possesses substantial capital and carries on a distinct business, meaning no employer-employee relationship exists between the principal bank and the contractor's employees; furthermore, the NLRC may validly consider evidence submitted for the first time on appeal to ascertain factual truths in labor cases.

Evidence

Ong Chia vs. Republic

(27th March 2000)

AK747857

385 Phil. 487 , 328 SCRA 749 , G.R. No. 127240

Ong Chia arrived in the Philippines from China in 1932 at the age of nine and lived there for over five decades, establishing a business and a family. In 1989, he filed a petition for naturalization under C.A. No. 473, asserting he possessed all qualifications and no disqualifications. While the trial court was initially satisfied with his testimony and knowledge of Philippine history, the State later discovered discrepancies between his current petition and a previous 1977 administrative application for naturalization.

The rule on the formal offer of evidence under Rule 132, Section 34 of the Rules of Court does not strictly apply to naturalization proceedings; pursuant to Rule 143 (now Rule 1, Section 4), the Rules of Court apply only by analogy or in a suppletory character in such cases, allowing the appellate court to consider documents presented by the State for the first time on appeal to ensure the applicant's full qualification for citizenship.

Evidence