Freyssinet Filipinas Corp. vs. Lapuz

Facts:

Amado R. Lapuz worked as a warehouse supervisor for what are now identified as related construction entities that operated under various names over time. He alleged continuous employment beginning in 1977 under predecessor companies (FF Interior; Freyssinet Post Tensioning System Philippines, Inc./Filsystem) and finally with Freyssinet Filipinas Corporation (FFC) up to 2012. He claims he was verbally told to leave in December 2011 and received a written termination notice dated January 5, 2012; believing the dismissal lacked substantive and procedural due process, he filed a complaint for illegal dismissal with the Labor Arbiter (LA), seeking reinstatement and other damages.

Petitioners (FFC and its officers) maintained that Lapuz was a project employee hired intermittently for specific projects, producing project employment contracts showing short-term engagements (notably several one-month contracts for the Wharton Parksuite project) and a termination report filed with the Department of Labor and Employment (DOLE) for the last project; they argued his service ended when the last project contract expired. They also denied that corporate officers should be held personally liable absent bad faith.

The LA (Decision dated January 26, 2014) found Lapuz to be a regular employee (tracing service to 1977 or long service) and held his dismissal illegal; it awarded separation pay (one month per year of service from 1977 to 2012), full backwages, P50,000.00 each as moral and exemplary damages, and 10% attorney’s fees. Petitioners appealed to the National Labor Relations Commission (NLRC).

The NLRC (Resolution dated April 30, 2014; Motion for Reconsideration denied June 25, 2014) reversed the LA, ruling Lapuz was a project employee whose engagement ended with the last project contract and thus was not illegally dismissed; it rejected awards for damages and attorney’s fees. Lapuz filed a petition for certiorari with the Court of Appeals (CA).

The CA (Decision dated April 20, 2016; Motion for Reconsideration denied August 23, 2016) granted certiorari, held the NLRC guilty of grave abuse of discretion, rei...(Pro-only)

Issues:

• Did the Court of Appeals commit reversible error in finding that the NLRC gravely abused its discretion?
• Was respondent Amado R. Lapuz a regular employee of FFC or a project employee?
• May the corporate officers be held personally liable for the monetary awards?
• Were the awards of moral and exe...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

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Doctrine:

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