Title
Capitol Industrial Construction Groups vs. National Labor Relations Commission
Case
G.R. No. 105359
Decision Date
Apr 22, 1993
Workers labeled as project employees performed essential, ongoing tasks, not tied to specific projects. SC ruled them regular employees, declaring dismissal illegal and upholding NLRC's reinstatement order.
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Case Digest (G.R. No. 105359)

Facts:

  1. Employment Contracts: The private respondents were hired by Capitol Industrial Construction Groups (petitioner) under contracts titled "Appointment as Project Contract Worker." These contracts stipulated that their employment was temporary, tied to specific projects, and would terminate upon project completion without entitlement to separation pay or regularization.
  2. Nature of Work: Despite being labeled as project employees, the private respondents were assigned to work at the company's Central Shop, Central Warehouse, or Central Office in Cainta, Rizal, performing tasks such as welding, inventory management, truck assistance, and machinery maintenance. These tasks were not limited to specific projects but were essential to the company's overall operations.
  3. Termination: On November 1, 1990, the petitioner terminated the private respondents' services, citing the completion of their projects. The private respondents filed a complaint for illegal dismissal.
  4. Labor Arbiter's Decision: The Labor Arbiter ruled that the private respondents were project employees whose employment ended with the completion of their projects. However, the Arbiter granted them separation benefits and service incentive leave pay.
  5. NLRC's Decision: The NLRC reversed the Labor Arbiter's decision, declaring the private respondents as regular employees, finding their dismissal illegal, and ordering their reinstatement with backwages and other benefits.

Issue:

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Ruling:

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Ratio:

  1. Regular Employment under Article 280 of the Labor Code: The Court emphasized that the nature of the work performed, not the employment contract's label, determines an employee's status. Since the private respondents performed tasks vital to the company's operations and were not limited to specific projects, they were regular employees.
  2. Project Employees vs. Regular Employees: Project employees are hired for specific projects with a predetermined completion date. In contrast, regular employees perform work necessary to the employer's business, regardless of the project's duration. The private respondents' continuous work beyond project completion and their assignment to central facilities confirmed their status as regular employees.
  3. Finality of NLRC's Factual Findings: The Court upheld the NLRC's factual findings, noting they were supported by substantial evidence and consistent with the realities of the construction industry.


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