Case Digest (G.R. No. 239622) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ruben Carpio v. Modair Manila Co. Ltd., Inc. (G.R. No. 239622, June 21, 2021), petitioner Ruben Carpio worked for respondent Modair Manila as an “Electrician 3” from October 27, 1998 until April 10, 2013. A Certificate of Employment confirmed this service, but Modair produced only project‐termination memoranda and contracts beginning in 2008, each stating that Carpio’s engagement would end upon completion of specific construction projects (Back End Expansion, PIL Green, UTIL Works, Ibiden CPU, NYK Tech Park). Carpio signed quitclaims and affidavits acknowledging project‐based terminations, yet in December 2013 he executed a new project agreement (FUNAI Project), an affidavit of desistance, and another quitclaim. Despite these instruments, Carpio filed before the Labor Arbiter a complaint for illegal dismissal and regularization, claiming he was not offered further work after the NYK Project. The Labor Arbiter dismissed his complaint (March 12, 2015), ruling that Carpio had in Case Digest (G.R. No. 239622) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Ruben Carpio filed a Petition for Review on Certiorari (July 18, 2018) assailing the Court of Appeals’ Decision (Dec. 27, 2017) and Resolution (Apr. 30, 2018) in CA-G.R. SP No. 143736.
- The CA had granted Modair Manila’s certiorari petition, setting aside the NLRC’s Decision (Sept. 29, 2015; Resolution Oct. 30, 2015) which affirmed Carpio’s regular status and ordered his reinstatement.
- Carpio’s Employment History
- Certificate of Employment (May 23, 2013) – Carpio was “contractor’s employee (per project basis), Electrician 3” from Oct. 27, 1998 to Apr. 10, 2013.
- Project engagements and terminations by Memoranda:
- IBIDEN Back End Expansion Project (terminated Aug. 15, 2008)
- PIL Green Construction Project (terminated Dec. 15, 2009)
- FAC D. UTIL Works Project (terminated Oct. 9, 2010)
- IBIDEN CPU S3 Project (terminated Aug. 10, 2012; Quitclaim Aug. 25, 2012)
- NYK Tech Park Project (Aug. 26, 2012–Apr. 10, 2013; Project Agreement Aug. 8, 2012; Quitclaims Apr. 25 & May 24, 2013)
- Alleged FUNAI Project Agreement (Dec. 11, 2013) with petty cash advances, desistance affidavit, and quitclaim.
- Proceedings Below
- Labor Arbiter Decision (Mar. 12, 2015): dismissed Carpio’s complaint for illegal dismissal and regularization, ruling he was project-based post-2000 resignation.
- NLRC Decision (Sept. 29, 2015) & Resolution (Oct. 30, 2015): reversed Arbiter, declared Carpio a regular employee since 1998, ordered reinstatement without backwages.
- Court of Appeals Decision (Dec. 27, 2017) & Resolution (Apr. 30, 2018): granted Modair’s certiorari, reinstated Arbiter, ruled Carpio project-based.
Issues:
- Whether Carpio was a project-based or regular employee of Modair.
- Whether Carpio was illegally dismissed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)