Facts:

The case involves Capitol Industrial Construction Groups as the petitioner and the National Labor Relations Commission (NLRC), along with several private respondents including Percival Granado (in his capacity as Sheriff of the NLRC), National Federations of Labor Unions (NAFLU), and individual employees Henry D. Monte, Arnel V. Lapore, Jose Painandos, Joel Ballebas, Antonio De Guzman, Roberto D. Villa, and Floro Cagomoc. The events leading to the case unfolded in Cainta, Rizal, where the private respondents were employed by the petitioner on various projects. Each respondent signed an employment contract titled "Appointment as Project Contract Worker," which stipulated that their employment was temporary and would terminate upon the completion of the project without any notice or entitlement to separation pay. On November 1, 1990, the petitioner terminated the services of the private respondents, claiming that their projects had been completed. Subsequently, the pr...

Facts:

Employment Contracts and Initial Engagement

• The private respondents were hired by the petitioner on various dates to work in its different projects.
• Before commencing work, each respondent executed an employment contract titled “Appointment as Project Contract Worker.”
• The contract explicitly stated that the respondents were contract workers engaged for specific projects.
• It provided that their employment was temporary and terminated upon the completion of the project without any entitlement to separation or termination pay.
• The contract also stipulated that completion or extension of the contract did not confer regular employee status.

Nature of Work and Place of Assignment

• Instead of being deployed strictly at project sites, the private respondents were assigned to other central facilities:
• Some worked as welders, truck helpers, machinists, or batterymen at the Central Shop.
• Others served as inventory clerks at the Central Warehouse.
• Several were stationed at the Central Office where administrative, engineering, auditing, and financing functions were performed.
• The roles performed at the central facilities were integral to the overall operation and administration of the petitioner’s various projects.

Termination of Employment and Subsequent Actions

• On November 1, 1990, petitioner terminated the services of the respondents on the ground that their respective project had been completed.
• In response, the private respondents filed a complaint for illegal dismissal against the petitioner and/or its personnel coordinator.

Decisions by Labor Arbiter and the NLRC

• The Labor Arbiter ruled that the respondents were project workers whose employment naturally ended upon the completion of their assignment.
• However, recognizing the respondents’ significant length of service, the Labor Arbiter still awarded separation benefits (at the rate of one-half month pay for every year of service) and service leave pay.
• The NLRC, on its review:
• Set aside the Labor Arbiter’s decision.
• Declared that the respondents were, in fact, regular employees.
• Found their dismissal illegal and ordered:
• Immediate reinstatement to their former positions without loss of seniority rights.
• Payment of backwages from the date of dismissal until actual reinstatement.
• Modified its relief by including the award of service incentive leave pay.

Petitioner’s Certiorari Petition and Defense

• The petitioner filed a petition for certiorari alleging grave abuse of discretion by the NLRC.
• The petitioner’s primary defense rested on the employment contract’s designation of the respondents as “Project Contract Workers.”
• It argued that the respondents’ employment tenure was naturally limited to the duration of the project for which they were hired.
• It further claimed that assigning workers to central facilities (for tasks such as maintenance or inventory management) did not violate the contractual stipulation of project-based employment.

Evidentiary and Legal Considerations

• Factual evidence presented revealed that the respondents performed functions essential and continuous to the petitioner’s business operations, not confined to a single project.
• Citing Article 280 of the Labor Code, which defines regular employment as involving activities “usually necessary or desirable in the usual business or trade” of the employer, the NLRC established that the respondents were regular employees.
• Precedents such as Magante vs. NLRC were referenced to support the interpretation that the nature of work and the place of assignment are determinative factors in establishing employment status.

Issue:

Whether the private respondents should be considered project employees as per the employment contract or regular employees based on the actual nature of their work.

• Determining if the contractual stipulation of “project worker” could override the factual work arrangements observed.
• Whether the evidence supports the conclusion that the respondents performed work that was integral to the petitioner’s ongoing projects and business operations.
• Whether the dismissal on the basis of project completion was justified given the actual roles and assignments of the employees.
• Whether the NLRC committed grave abuse of discretion in declaring the respondents as regular employees and ordering their reinstatement with full backwages and benefits.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)