Facts:

In the case of Banana Growers Collective at Puyod Farms vs. National Labor Relations Commission, the petitioners, which include Cynthia P. A. Zafra, Milagros P. Cegsiaco, Marcela Puyod, Luciano Puyod II, Myrna P. Solski, Concepcion P. Yulo, Mauro Puyod, Sylvia P. Rieta, and Jacquelene P. Marcelino, are the heirs of Federico Puyod, Sr. who operated a banana farm in Mabuhay, Carmen, Davao del Norte. The respondent agricultural workers were hired in 1988, while two additional workers, Rio Bernal and Nestor Amperias, joined in January 1989. The farm operations included various tasks such as spraying, bagging, injecting chemicals, weeding, pruning, and adeleafing. In light of business growth from planting Cavendish bananas for export, a Banana Growers Collective was formed.

The significant turn of events occurred when Federico Puyod, Sr. passed away; his heirs subsequently partitioned Puyod Farms among themselves and began managing their respective shares separately. In 1990, STANFIL

Facts:

Federico Puyod, Sr. owned a banana farm operated under the name Puyod Farms in Carmen, Davao del Norte. After his demise, his heirs—Cynthia P. Zafra, Milagros P. Cegsiaco, Marcela Puyod, Luciano Puyod II, Myrna P. Solski, Concepcion P. Yulo, Mauro Puyod, Sylvia P. Rieta, and Jacquelene P. Marcelino—partitioned and managed portions of the farm individually. Previously, the Banana Growers Collective was in operation, but the partition ultimately led to its dissolution. In 1988 and early 1989, the farms hired private respondent workers for tasks such as spraying, bagging, chemical injection, and general farm maintenance. The farms had entered a contract with STANFILCO, which required converting part of the banana plantations (from giant Cavendish to Ecuadorian dwarf banana variety) and mandated reduction in manpower during the conversion period. On January 30, 1990, the heirs received a letter from STANFILCO informing them about the conversion process and the need to reduce regular labor force. Consequently, on February 2, 1990, the petitioners (the heirs) notified the workers of their retrenchment—effective 30 days later—citing compliance with their contractual obligation with STANFILCO. Prior to the retrenchment, in September 1989, some of the private respondents had organized a labor union and even filed a petition for certification election. They subsequently disputed their dismissal, alleging that the retrenchment was a mere pretext to target them for union activities, especially since workers in some converted farms were retained and additional workers were hired for replanting in other areas. The Labor Arbiter initially ruled in favor of the petitioners, holding that retrenchment was an exercise of managerial prerogative based on economic grounds, and that proper procedural due process had been observed. However, the National Labor Relations Commission (NLRC) reversed that decision, finding that the petitioners failed to prove the imminent and substantial losses claimed, and that the dismissal appeared selectively targeted to suppress union activities.

Issue:

1. Whether the retrenchment of private respondent agricultural workers was effectuated in compliance with the substantive and procedural requisites mandated by law.
2. Whether the petitioners (heirs) sufficiently proved that the retrenchment was necessary to prevent imminent and substantial losses arising from their contractual obligations with STANFILCO.
3. Whether the retrenchment, in the context of farm conversion operations and pending union certification elections, was merely a pretext to terminate workers for engaging in union activities.

Ruling:

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Ratio:

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Doctrine:

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