San Miguel Corporation v. NLRC

Summary

134 workers employed by Reliable Labor Contractor sued for unpaid 13th month pay while performing services for San Miguel Corporation. The case established the principle of solidary liability between principal companies and labor contractors for employee benefits. Despite San Miguel's argument that P.D. 851 does not provide for solidary liability, the Supreme Court applied Labor Code provisions (Articles 106-109) to hold that indirect employers are jointly liable with contractors for wage violations. The decision strengthened worker protection by ensuring that principal companies cannot escape liability for contractor violations, affirming the constitutional mandate of labor protection and the solidary liability doctrine in labor contracting arrangements.