Case Digest (G.R. No. L-15955)
Facts:
In Policarpo Capule and Luis Madoro v. National Labor Relations Commission, petitioners Policarpo Capule and Luis Madoro were hired by Yakult Philippines, Inc. to cut cogon grass and weeds at the back of its factory building without any fixed schedule, working at their own discretion. On July 13, 1987, their services were terminated and they filed a complaint for illegal dismissal before the Labor Arbiter. On September 20, 1988, the Arbiter ruled in their favor, ordering reinstatement with full back wages and retention of seniority rights. Yakult appealed to the National Labor Relations Commission (NLRC), which on September 18, 1989, set aside the Arbiter’s decision and awarded petitioners one month’s pay each on humanitarian grounds. Petitioners then filed a petition for certiorari with the Supreme Court, alleging grave abuse of discretion and invoking Article 4 of the Labor Code and ArticlCase Digest (G.R. No. L-15955)
Facts:
- Nature of Petition
- Petitioners challenge their dismissal before the completion of one year’s service and seek relief via certiorari against the NLRC.
- The central controversy is whether casual or temporary employees may be lawfully dismissed before one year.
- Employment Background and Termination
- Private respondent Yakult Philippines, Inc. is engaged in the manufacture of cultured milk.
- Petitioners were hired to cut cogon grass and weeds on the factory premises, with no fixed schedule and working at their discretion.
- Their services were terminated on July 13, 1987, allegedly due to unsatisfactory performance.
- Procedural History
- Petitioners filed a complaint for illegal dismissal with the NLRC; the Labor Arbiter (Sept. 20, 1988) found the dismissal illegal and ordered reinstatement with full backwages.
- On appeal, the NLRC (Sept. 18, 1989) set aside that decision and granted petitioners one month’s pay each on humanitarian grounds.
- Petitioners elevated the case to the Supreme Court via a petition for certiorari, alleging grave abuse of discretion by the NLRC.
Issues:
- Whether petitioners, as casual or temporary employees, may be dismissed before the expiration of one year of service.
- Whether the cutting of cogon grass constitutes work “usually necessary or desirable” in the usual business of Yakult and thus renders petitioners regular employees.
- Whether dismissal before one year gives rise to a valid claim for illegal dismissal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)