Facts:

The case involves Amado R. Lapuz (respondent) against Freyssinet Filipinas Corporation (now Frey-Fil Corporation), Eric A. Cruz, Gaudencio S. Reyes, and Carlota R. Satorre (petitioners). Respondent worked as a warehouse supervisor for Freyssinet Filipinas Corporation, a company engaged in general construction and related activities. He claimed to have been employed since 1977 under various company names, including FF Interior, Freyssinet Post Tensioning System Philippines, Inc. (FPTSPI), and FFC. His last assignment was at the Wharton Parksuite Project in Binondo, Manila. In December 2011, he was verbally informed of his termination by project manager Reyes, which he contested as illegal due to lack of due process. Respondent filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC), asserting that he was a regular employee entitled to reinstatement and other benefits.

Petitioners contended that respondent was a project employee, hired on...

Facts:

Employment History and Termination:

• Respondent Amado R. Lapuz worked as a warehouse supervisor for petitioner Freyssinet Filipinas Corporation (FFC), now Frey-Fil Corporation, a domestic corporation engaged in general construction, pre-stressed, and post-tensioning businesses.
• Lapuz claimed he started working for FFC in 1977 under its previous company names: FF Interior (1977-1982), Freyssinet Post Tensioning System Philippines, Inc. (FPTSPI) or Filsystem (1982-1999), and FFC (2006-2012).
• Lapuz was assigned to various projects, with his last assignment at the Wharton Parksuite Project in Binondo, Manila.
• In December 2011, Lapuz was verbally informed of his termination by project manager Gaudencio S. Reyes and was later given a formal notice of termination on January 5, 2012.
• Lapuz filed a complaint for illegal dismissal, seeking reinstatement and payment of attorney's fees.

Petitioners' Defense:

• Petitioners argued that Lapuz was hired on a project basis, starting on April 11, 2007, for the Texas Instruments project in Pampanga, and was subsequently rehired for other projects, including the Wharton Parksuite project, which ended on December 31, 2011.
• They submitted project employment contracts and claimed that Lapuz's termination was reported to the Department of Labor and Employment (DOLE) as required by law.
• Petitioners maintained that Lapuz was not illegally dismissed but that his project employment contract had expired.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Regular Employment:

   • Under Article 295 of the Labor Code, regular employment exists when an employee performs tasks that are usually necessary or desirable in the employer's business. Lapuz's role as a warehouse supervisor was integral to FFC's construction business, and his continuous rehiring across multiple projects indicated regular employment.

2. Project Employment:

   • For an employee to be considered a project employee, the employer must prove that the employee was hired for a specific project with a determined duration. The Court found that petitioners failed to prove this, as Lapuz was repeatedly rehired for the same tasks without interruption.

3. Illegal Dismissal:

   • Regular employees are entitled to security of tenure and can only be dismissed for just or authorized causes. Since Lapuz was a regular employee and his dismissal was not based on a valid cause, his termination was illegal.

4. Corporate Liability:

   • Corporate officers can only be held personally liable if they acted in bad faith or were grossly negligent. In this case, there was no evidence of such conduct, so the corporate officers were not held liable.

5. Damages:

   • Moral and exemplary damages require proof of bad faith, fraud, or oppressive conduct. Since no such evidence was presented, the Court deleted the awards for these damages.

Final Decision:

• The Supreme Court partly granted the petition, affirming the CA's ruling that Lapuz was a regular employee and was illegally dismissed.
• The Court modified the CA's decision by:
  • Limiting Lapuz's separation pay to his employment period starting from April 11, 2007.
  • Absolving the corporate officers from liability.
  • Deleting the awards for moral and exemplary damages.