Title
Hanjin Heavy Industries and Construction Co. Ltd. vs. Ibanez
Case
G.R. No. 170181
Decision Date
Jun 26, 2008
Hanjin dismissed workers, claiming project completion; courts ruled them regular employees, illegally terminated, entitled to backwages and separation pay.

Case Digest (G.R. No. 170181)
Expanded Legal Reasoning Model

Facts:

  • Parties and Employment Context
    • Petitioners: Hanjin Heavy Industries and Construction Co. Ltd. (HANJIN), a foreign construction company registered in the Philippines, and its employees Hak Kon Kim (Project Director) and Jhunie Adajar (Supervisor).
    • Respondents: Felicito IbaAez, Ligwas Carolino, Elmer Gacula, Enrique Dagotdot, Ruel Calda, and others, alleged employees of HANJIN.
    • Respondents filed a complaint for illegal dismissal before the NLRC in 2002, claiming regular employment status and praying for reinstatement and backwages.
  • Employment Details and Allegations
    • Respondents alleged hire dates ranging from 1992 to 2000 and held various positions (e.g., tireman, crane operator, welder, warehouseman).
    • They stated their tasks were usual and necessary in HANJIN’s business and that they were part of a work pool assigned to multiple projects (North Harbor, Manila International Port, Batangas Port, Batangas Pier, La Mesa Dam).
    • Respondents claimed illegal dismissal on 15 April 2002 despite ongoing HANJIN projects such as MRT II and MRT III and alleged the company continued hiring replacements.
  • Petitioners' Defense
    • Petitioners contended respondents were project employees hired with three-month contracts specifically for LRT/MRT Line 2 Project packages 2 and 3.
    • Petitioners claimed employment contracts stipulated project-based employment, automatic renewal unless terminated, and termination upon project completion.
    • Petitioners failed to submit copies of these contracts.
    • HANJIN alleged proper notice of downsizing was given before dismissal, supported by a Termination Report filed with the Department of Labor and Employment (DOLE).
    • Petitioners argued payment of completion bonuses evidenced project employee status, supported by payroll records annotated with "completion bonus."
    • Quitclaims and clearances signed by respondents were presented to indicate receipt of all due benefits and release of claims.
  • Proceedings Below
    • Labor Arbiter ruled respondents were regular employees illegally dismissed, citing failure of petitioners to prove project employee status and noting respondents’ lengthy service. Ordered reinstatement, backwages, damages, and litigation expenses.
    • NLRC reversed Labor Arbiter decision, holding respondents were project employees who were legally terminated, giving weight to the Termination Report, completion bonuses, and quitclaims. Also deleted damages awarded by Labor Arbiter.
    • Court of Appeals reversed NLRC, ruling respondents were regular employees illegally dismissed. Found petitioners’ shifting claims and lack of written contracts weakened their position; considered termination report insufficient to prove project employee status. Adopted NLRC’s deletion of damages but reinstated awards for backwages, separation pay, and litigation expenses.
  • Present Petition and Issues Raised
    • Petitioners question the thoroughness of Court of Appeals’ factual findings.
    • Allegation of ignoring relevant facts would yield a different result.
    • Claim that Court of Appeals erred in applying Department Order No. 19 and Article 280 of the Labor Code concerning project employees.
    • Contention that respondents were legally dismissed.

Issues:

  • Whether the Court of Appeals erred in declaring respondents as regular employees despite petitioners’ claim that they were project employees.
  • Whether petitioners proved the existence and terms of respondents’ project employment contracts.
  • Whether the Court of Appeals properly evaluated the submission and evidentiary value of the Termination Report filed with DOLE and the payment of completion bonuses.
  • Whether respondents’ dismissal was legal and complied with due process requirements.
  • Whether the Court of Appeals manifestly overlooked facts or applied incorrect legal standards under policy instructions and the Labor Code.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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