Case Digest (G.R. No. 116572)
Facts:
The case revolves around the petitioner, D. M. Consunji, Inc., and the respondents, Alexander Agraviador, Jovencio Mendrez, Felipe Barcelona, Consorcio Laspuna, and Rogelio Diaz, who were engaged as project employees for the Cebu Super Block Project in Cebu City. The private respondents entered into separate but standardized contracts for a month-long employment period, with specific roles and remuneration. Their contracts explicitly stated that their employment would last for an estimated duration tied to the project and could be terminated earlier for various justifiable reasons, including the completion of the project phase.On March 2, 1993, their employment was abruptly ended, prompting the respondents to lodge complaints for illegal dismissal with a request for reinstatement and full backwages. The Labor Arbiter ruled in favor of the respondents, deeming their dismissal unlawful as it was executed without just cause and prior to the expiration of their contracts. The dec
Case Digest (G.R. No. 116572)
Facts:
- Background of Employment
- Petitioner, D. M. Consunji, Inc., employed private respondents for its Cebu Super Block Project in Cebu City.
- The private respondents—Alexander Agraviador, Jovencio Mendrez, Felipe Barcelona, Consorcio Laspuna, and Rogelio Diaz—were hired under separate but identical contracts.
- The contracts specified:
- Appointment as project employees for an estimated period of one month, which was linked to the duration or phase of the project.
- Conditions including early termination for unsatisfactory services, completion of the project or any phase thereof, or any justifiable cause.
- The possibility for private respondents to be considered for other available projects if one was completed.
- Termination of Services
- On March 2, 1993, petitioner terminated the services of the private respondents.
- The termination was alleged to be due to the expiration of the contracts.
- However, evidence showed that while some contracts had expired, others (specifically those of Agraviador and Mendrez) had not yet reached the designated termination date.
- The termination led to a dispute regarding whether the dismissals were in accordance with the contractual terms.
- Labor Arbitration and NLRC Proceedings
- Private respondents filed complaints for illegal dismissal, claiming that they were terminated without just cause and without due process.
- The Labor Arbiter ruled in favor of the private respondents:
- Found that despite signing contracts for a fixed term, the dismissals were not solely based on the expiry of the contracts.
- Ordered the reinstatement of the respondents along with full backwages (each awarded P5,460, amounting to a total of P27,300).
- The decision of the Labor Arbiter was affirmed by the National Labor Relations Commission (NLRC).
- Petition for Certiorari
- Dissatisfied with the NLRC’s decision, petitioner elevated the case via a special civil action of certiorari under Rule 65.
- Petitioner contended that:
- The private respondents were project employees, hired strictly on a project-to-project basis.
- As project employees, they were not entitled to reinstatement or full backwages.
- The NLRC’s order for reinstatement demonstrated grave abuse of discretion amounting to lack of jurisdiction.
- The Office of the Solicitor General supported petitioner’s position by recommending the reversal of the NLRC decision.
- Nature of the Project Employment
- The contracts clearly indicated that employment was tied to a specific project:
- Employment was fixed for one month, the estimated period for the completion of the Cebu Super Block Project.
- Termination could occur upon the fulfillment of one of the specified conditions, including the completion of the project or a phase thereof, or for other just cause.
- Although private respondents claimed illegal dismissal because they were dismissed before the completion of the project, they admitted that they understood their status as project employees, which inherently limits their claim to reinstatement.
Issues:
- The Status of the Private Respondents
- Whether the private respondents should be classified as project employees based on the fixed-term, project-specific nature of their contracts.
- Whether their understanding and admission of being project employees precludes them from claiming regular employment benefits.
- Legality of the Termination
- Whether the termination of the services of the private respondents was effected with just cause.
- Specifically, whether terminating employees (Agraviador and Mendrez) before the expiration of their contractual period constitutes illegal dismissal.
- Jurisdiction and Abuse of Discretion by the NLRC
- Whether the NLRC acted with grave abuse of discretion by ordering reinstatement and full backwages.
- Whether the petitioner's argument—that project employees are not entitled to such remedies—is supported by the terms of the contracts and applicable law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)