G.R. No. 237020 - Inocentes vs. R. Syjuco Construction, Inc.

The petitioners – Dominic Inocentes, Reymark Catangui, Jeffrey Inocentes, and Joseph Cornelio – filed a complaint against R. Syjuco Construction, Inc. (RSCI) and its owner, Ryan Syjuco.
They alleged that RSCI employed them as construction workers on a night shift from 7:00 p.m. to 7:00 a.m. without providing night differential, overtime, rest day pay, service incentive leave pay, ECOLA, 13th month pay, holiday premium pay, or the mandated minimum wage.
The petitioners claimed that, for over a year, they worked on a no-work-no-pay basis.
On separate dates in September 2015, the workers reported for duty only to be denied entry at the jobsite, with the security guard informing them that they had been terminated.
They further contended that they were not given any opportunity to explain or seek redress on the spot, thereby asserting that their dismissal was constructively executed without due process.
In their pleadings, the petitioners maintained that they were regular employees and denied ever having worked on a project basis, criticizing RSCI for the absence of employment contracts that would indicate project-specific engagements.

RSCI and Ryan Syjuco contended that the petitioners were engaged as carpenters on a project basis, rather than as regular employees.
They explained that the petitioners were hired in phases: Dominic and Reymark in 2009, Jeffrey in 2010, and Joseph in 2012, with each assignment tied to short-term projects.
The respondents argued that the nature of their business—mainly involved in small-scale construction or repair/renovation projects—necessitated a project-based employment structure, where work assignments naturally ended with project completion.
They relied on a summary of project assignments and the corresponding length of service to support their claim, asserting that these documents served as notice to the petitioners regarding the temporary nature of their engagement.
In subsequent submissions, respondents maintained that the absence of a written employment contract was not fatal to the characterization of the engagement as project-based and contended that termination due to project completion or contract expiration was valid.

The LA dismissed the illegal dismissal claim but found merit in the petitioners’ claims for underpayment of salaries, overtime, 13th month pay, and for certain workers, holiday premium pay.
The LA also awarded nominal damages of ₱5,000.00, holding that the petitioners were project employees since they did not specifically allege or prove uninterrupted, continuous work.

The NLRC partially reversed the LA’s findings by ruling that the petitioners were regular employees who were illegally dismissed.
It ordered RSCI to pay backwages, separation pay, service incentive leave pay, and attorney’s fees (amounting to 10% of the monetary award), while still affirming the LA decision on other underpayment claims.
The NLRC based its ruling on the failure of RSCI to comply with the DOLE’s reportorial requirements for project employees, suggesting that non-compliance implied a regular employment status.

The CA annulled the NLRC decision and reinstated the LA decision, concluding that the petitioners were project employees.
The CA’s ruling was premised on the contention that the key test for project employment was whether the employees were engaged for a specific project with a predetermined scope and duration, as evidenced by the project assignment summaries.
The CA denied the motion for reconsideration filed by the petitioners.

The petitioners challenged the CA decision in a Petition for Review on Certiorari, raising issues about whether the CA committed reversible error in reversing the NLRC decision.
They contended that the absence of employment contracts and proper notice of project-based engagement undermined the respondents’ evidence, thereby confirming their status as regular employees who were illegally dismissed.

Whether the Court of Appeals committed reversible error by annulling the NLRC decision, which held that the petitioners were regular employees who were illegally dismissed, thereby denying them their money claims.
Whether the absence of formal employment contracts specifying project employment, along with the failure to comply with DOLE reportorial requirements, precludes RSCI from successfully classifying the petitioners as project employees.
Whether the termination of the petitioners—who were allegedly dismissed without notice and due process—constitutes an illegal dismissal of regular employees.