G.R. No. 112535 - Cinderella Marketing Corp. vs. National Labor Relations Commission

Cinderella Marketing Corporation, a duly organized and existing corporation under Philippine laws, is the petitioner, with its principal office located at 825 Epifanio de los Santos Avenue, Quezon City.
The private respondents are employees hired on a seasonal basis to perform various roles including salesladies, wrappers, stockmen, and pressers, which are integral to the company’s usual business.

The company traditionally hires additional employees during its peak season—running from September until January—to meet increased operational demands.
This practice of temporary hiring was established prior to the 1988 Collective Bargaining Agreement (CBA) negotiations and was later modified through negotiations with the union.

Under the negotiated CBA, seasonal employees designated as “regular contractuals” were to be afforded benefits similar to regular employees once promoted or regularized, including security of tenure, minimum wage, overtime pay, and other statutory benefits.
Despite being regarded as regular employees from the start, these workers were initially excluded from the bargaining unit until their formal regularization and subsequent inclusion in a newly-opened branch, triggering their membership benefits.

Dissatisfied with their exclusion from the bargaining unit and the resulting deprivation of benefits under the CBA, the private respondents repeatedly demanded inclusion.
Failing to secure a favorable resolution through internal negotiations, they filed a complaint with the National Labor Relations Commission (NLRC) seeking, among others, full CBA benefits, back wages, and the regularization differential for the period from completion of one year of service until their promotion or regularization.

At the initial stage, the Labor Arbiter declared the respondents as regular rank-and-file employees and ordered the petitioner to pay the benefits granted under the CBA, including back benefits.
The NLRC, on appeal, affirmed the Labor Arbiter’s decision, and subsequent motions for reconsideration were denied, confirming both the inclusion of the respondents in the bargaining unit and their entitlement to regular employee benefits.

The petitioner contended that although the employees eventually become regular employees upon promotion or regularization, they should not receive the regularization differential for the period in which they were still considered seasonal employees.
The petitioner argued that there existed a semantic distinction in the CBA between “regular employees” and “regular contractual employees,” thereby justifying the exclusion of the latter from certain benefits until formally regularized.
Additionally, the petitioner challenged the jurisdiction of the NLRC by asserting that the dispute involved interpretation or implementation of the CBA—a matter it believed should be subjected to voluntary arbitration rather than resolved by the NLRC.

The petitioner invoked Article 217(c) of the Labor Code, arguing that issues arising from the interpretation of collective bargaining agreements should fall under voluntary arbitration.
However, the case centered on a claim for benefits arising from the employer-employee relationship and involving monetary claims exceeding ₱5,000, which falls squarely under the exclusive jurisdiction of the Labor Arbiter and NLRC pursuant to Article 217(a)(6) of the Labor Code.

Detailed computations were presented for each private respondent, with individual claims ranging approximately between ₱12,440.06 and ₱32,861.94.
These computations underscored the significant monetary stakes involved and reinforced the appropriateness of the NLRC’s jurisdiction given that each claim exceeded the ₱5,000 threshold.

The Court found that the NLRC did not commit grave abuse of discretion in its rulings.
It upheld the interpretation that employees who have rendered at least one year of service under Article 280 of the Labor Code must be considered regular employees, regardless of the contractual nuances presented by the petitioner.
Consequently, the petition seeking to annul and set aside the NLRC Resolutions was dismissed for lack of merit, and the petitioner’s arguments were rejected.

Whether the NLRC committed grave abuse of discretion in deeming the seasonal employees as regular employees subject to the benefits of the CBA.
Whether the classification of “regular contractual employees” as distinct from regular employees is legally tenable under the provisions of the Labor Code.
Whether the exclusion of seasonal employees from the bargaining unit until their promotion or regularization is consistent with statutory labor protections.
Whether claims for back benefits, including the regularization differential for services rendered after one year, fall within the exclusive jurisdiction of the NLRC and Labor Arbiter.