G.R. No. 220087 - Hacienda San Isidro/Silos Farms and Rey Silos Llamado vs. Lucito Villaruel and Helen Villaruel

Spouses Lucito Villaruel and Helen Villaruel were employed at Hacienda San Isidro, part of Silos Farms in Himamaylan, Negros Occidental, which was administered by Rey Silos Llamado and owned by Fidel Silos.
The work performed involved sugarcane cultivation, counting patdan (canepoints), and other tasks associated with sugar farming – activities that are seasonal in nature yet integral to the usual business operations of the hacienda.

In separate complaints filed on December 18, 2009, and April 7, 2010, before the National Labor Relations Commission (NLRC), the Spouses Villaruel sought relief for illegal dismissal, underpayment of wages, non-payment of service incentive leave pay, and attorney’s fees. The cases were consolidated and reassigned to a single Labor Arbiter.
On February 14, 2011, the Labor Arbiter rendered a decision declaring:

Lucito Villaruel’s dismissal as being for a just cause but without due process, along with an award in the form of nominal damages.
Helen Villaruel as a regular employee who had been illegally dismissed, directing petitioners to pay backwages and separation pay computed in accordance with her tenure.

Subsequent filings included a Memorandum of Partial Appeal by petitioners (April 11, 2011) and oppositions by respondents, resulting in a modified NLRC decision on September 30, 2011. This decision:

A Motion for Reconsideration by the Spouses Villaruel led the NLRC, on January 27, 2012, to reinstate the Labor Arbiter’s original findings, unanimously declaring both dismissals illegal and ordering appropriate awards.
Petitioners further filed motions and a Petition for Certiorari before the Court of Appeals (CA). Initially, the CA ruled (March 27, 2013) that Helen was not an employee based on insufficient evidence of an employer-employee relationship, particularly lacking proof of the employer’s power of control.
On May 27, 2013, the Spouses Villaruel’s motion for reconsideration led the CA, by its Amended Decision dated January 9, 2015, to reverse its earlier ruling and declare Helen as a regular employee. The CA based this determination on:

Helen’s engagement to perform necessary or desirable tasks in the usual business of the petitioners.
Her employment pattern, which entailed being repeatedly hired over several seasons.

Petitioners challenged the Amended Decision by filing a Motion for Partial Reconsideration (February 11, 2015) which was denied on July 20, 2015.
The case eventually reached the Supreme Court via a Petition for Review on Certiorari, wherein the sole issue raised was whether Helen, as a seasonal worker, should be considered a regular employee.

It is uncontested that Helen was a seasonal worker; her tasks were seasonal, being performed during specific harvest periods.
Petitioners argued:

Helen’s status as a pakyaw (task-based) worker and her freedom to contract with other farm owners negated the supervisory power, thereby excluding her from the employer-employee relationship.
Her intermittent hiring and the flexibility shown in her work schedule further supported the contention that she was not subject to the petitioners’ control.

There was no evidence that Helen ever offered her services to other haciendas or farm owners.
Documentation (affidavits and payroll records) corroborated her regular and continuous engagement with the petitioners over several seasons.
That the method of compensation (pakyaw) was merely a payment scheme and did not affect the existence of an employer-employee relationship.

Whether Helen, as a seasonal worker in a sugar plantation, qualifies as a regular employee under Article 280 (now Article 295) of the Labor Code.

Does the continuous and repeated engagement over multiple harvesting seasons remove her from the exception reserved for seasonal workers?
Is the fact that she was paid under a pakyaw scheme conclusive in negating the employment relationship, particularly the power of control or supervision?
Does her freedom to contract her services with other employers affect her status as a regular employee when she was, in practice, continuously rehired for the same activities?