Case Digest (G.R. No. 149440)
Facts:
In Hacienda Fatima and/or Patricio Villegas, Alfonso Villegas and Cristine Segura v. National Federation of Sugarcane Workers–Food and General Trade (G.R. No. 149440, January 28, 2003), petitioners are the owners of Hacienda Fátima in Negros Occidental, while respondents are sugarcane workers who organized into a union certified in late 1990. After securing certification, the workers demanded collective bargaining; petitioners refused, alleging the certification was still on appeal, and hired replacements during the off‐season. Respondents staged a strike in January 1991, settled via a Memorandum of Agreement providing for negotiations and priority work assignments, but petitioners reneged, used armed guards to bar union organizers, and failed to give work assignments beginning September 1991. A second strike in January 1992 led to another Memorandum of Agreement to determine union members’ status and reinstatement. When petitioners again refused, respondents filed unfair laborCase Digest (G.R. No. 149440)
Facts:
- Nature of Employment
- Respondents were engaged as sugarcane workers for petitioners’ hacienda operations, performing season-based tasks.
- Although the work was seasonal, respondents were rehired for multiple seasons over several years.
- Formation of the Union and First Labor Dispute
- Respondents organized the National Federation of Sugarcane Workers and won certification as the collective bargaining representative.
- Petitioners, under the pretext of an appeal, refused to negotiate a collective bargaining agreement and did not assign work for over a month.
- In protest, respondents staged a strike which ended in a January 4, 1990, Memorandum of Agreement (MOA) providing for:
- CBA negotiations to commence January 11, 1991, to conclude within 30 days.
- Priority dispatch of women union members and reinstatement of normal workloads.
- Provision of 15 wagons, prioritization of pre-strike workforce, and exclusion of approximately 18 scab workers.
- Petitioners reneged on the MOA, refused to bargain further, employed private armed guards, and ceased work assignments beginning September 1991.
- Second Labor Dispute and Procedural History
- Respondents struck again on January 2, 1992; a second MOA dated January 23, 1992, was signed, establishing a joint committee to verify the status of 36 union members against the 1990 payroll and prior agreements, with voluntary arbitration for disputes.
- Minutes of conciliation listed certain employees for immediate reinstatement; petitioners again failed to comply.
- Respondents filed complaints before the Labor Arbiter for illegal dismissal and unfair labor practice; the Labor Arbiter’s decision was set aside by the NLRC, which ordered reinstatement (except four named individuals), full backwages from September 1991, and awarded moral (₱10,000) and exemplary damages (₱5,000) for unfair labor practice.
- The Court of Appeals denied petitioners’ certiorari petition, affirming the NLRC’s findings and rulings. Petitioners then elevated the case to the Supreme Court via Rule 45 petition.
Issues:
- Whether the Court of Appeals erred in ruling that respondents, though seasonal workers, are regular employees under Article 280 of the Labor Code (including the applicability of Mercado v. NLRC versus other precedents).
- Whether the Court of Appeals gravely abused its discretion in upholding the finding of illegal dismissal, unfair labor practice, and the award of moral and exemplary damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)