G.R. No. 86408 - Beta Electric Corp. vs. National Labor Relations Commission

The petitioner, Beta Electric Corporation, hired the private respondent as clerk typist III effective December 15, 1986.
The initial engagement was supported by a written contract which set the terms of her employment.

The employment was extended on January 16, 1987, by means of a subsequent written contract.
Further extensions were granted on February 15, 1987; March 15, 1987; April 30, 1987; May 31, 1987; and finally up to June 30, 1987, each evidenced by a corresponding written contract.

On June 22, 1987, the private respondent’s services were terminated without prior notice or any form of investigation.
On the same day, the private respondent filed a complaint for illegal dismissal before a labor arbiter.

The labor arbiter ruled in favor of the private respondent, finding the dismissal illegal.
The National Labor Relations Commission (NLRC) affirmed the decision of the labor arbiter, solidifying the legal support for the employee’s claim.

The petitioner contended that the private respondent was hired on a temporary, contract-to-contract basis, meant solely for meeting seasonal or peak demands.
It argued that her employment was temporary, implying that termination could lawfully occur after the accomplishment of a specific task.
The petitioner maintained that the successive contracts indicated a temporary engagement, rather than an employment status that accrued the benefits of regularization.

Despite the contract-to-contract arrangement, the actual work performed by the private respondent—acting as typist-clerk—was integral and usual to the business.
Under Article 281 of the Labor Code, an employee rendered regular upon completing the probationary period was identified, independent of the form of the contract.
The courts viewed the successive contracts as an artifice intended to prevent the private respondent from obtaining security of tenure.
The nature of the work did not qualify as a “specific undertaking” or “seasonal” task, thus mandating regular employment status by operation of law.

Whether a series of contract-to-contract appointments could still give rise to a regular employment status under the Labor Code.
Whether the employee’s work as a typist-clerk, being an activity “usually necessary or desirable in the usual business,” negated the argument for temporary employment.

Whether the termination of the employee, after the expiration of successive contracts and beyond the probationary period, constituted an illegal dismissal.
Whether the petitioner’s assertion that the employee was merely working on a temporary basis was tenable in light of the statutory conversion to regular employment after six months.

Whether contractual stipulations regarding the duration of employment could override provisions of the Labor Code.
Whether the concept of a “specific undertaking” applied in this case, considering the integral and continuous nature of the work performed.