G.R. No. 96161 - Philips Export B.V. vs. Court of Appeals

Petitioners (Isidro Quebral, Alberto Esquillo, Renante Salinsan, Jerome Macandog, Edgardo Gayorgor, Jim Robert Perfecto, Noel Perfecto, Dennis Pagayon, and Herculano Macandog) were employed as construction workers.
They were engaged by respondent Angbus Construction, Inc. on various dates from 2008 to 2011 and claimed to be regular employees because they performed tasks necessary to the usual construction business.
It was alleged that the petitioners had been continuously employed, having rendered services for several years to Angbus, thus establishing regular employment.

Petitioners were summarily dismissed on June 28, 2012 and July 14, 2012 without just or authorized cause and without due process.
They filed consolidated cases seeking reinstatement and payment of full backwages, salary differential, 13th month pay, service incentive leave pay, overtime and holiday pay, as well as moral and exemplary damages and attorney’s fees.
The central factual dispute revolved around whether petitioners were engaged as regular employees or merely as project-based workers with predetermined employment durations.

Respondents (Angbus Construction, Inc. and Angelo Bustamante) argued that petitioners were employed for specific projects only—first with Angelfe Management and Consultancy for a one-time project and later with Angbus for another project.
They claimed that the gap between the two project engagements showed non-continuous employment and that petitioners were hired only for limited durations.
Respondents attempted to justify the absence of employment contracts, payrolls, and job application records by alleging that these documents were destroyed by flood, as evidenced by the Barangay Rosario Certification issued by the local barangay captain in Rosario, Pasig City.

The LA ruled that petitioners were not illegally dismissed and classified them as project employees, emphasizing that the specific project-based hiring was an industry practice in the construction business.
Despite the absence of original employment contracts (attributed to flood damage), the LA relied on the Establishment Employment Reports submitted to the Department of Labor and Employment (DOLE) to support the conclusion of project termination.
The LA ordered Angbus and Angelfe to pay salary differentials, 13th month pay, and holiday pay as admitted liabilities, while Angelo Bustamante was absolved from any payment.

The NLRC reversed the LA’s ruling by declaring that petitioners were regular employees who were illegally dismissed, entitling them to reinstatement and full backwages along with other monetary claims.
The NLRC emphasized that respondents failed to present employment contracts to rebut the regular employment claim and noted inconsistencies in the respondents’ evidence—particularly regarding the improper location of the Barangay Rosario Certification (the business address was in Quezon City).
The NLRC found that the simultaneous hiring of petitioners in 2012 and the absence of project-specific evidence pointed toward a continuous and regular employment relationship.
A subsequent NLRC Resolution (December 29, 2014) denied respondents’ motion for reconsideration, affirming that petitioners’ appeal had been timely filed and that the absence of employment records in the main office could not be justified by temporary project-site conditions.

The CA held that the NLRC gravely abused its discretion by (i) giving due course to the appeal allegedly filed out of time and (ii) ruling that petitioners were regular employees.
In reviewing the timeliness of the filing, the CA discounted the evidentiary value of the registry receipt and related certifications due to questions about their authentication and issuance timing (noting that Laureta’s certification was rendered after her assignment ended).
Substantively, the CA reinstated the LA’s finding by classifying petitioners as project employees, contending that the absence of project employment contracts did not automatically confer regular status.
As a consequence, the CA ordered respondents to return any amounts paid under the NLRC decision.

Petitioners, disagreeing with the CA’s decision – particularly its findings on the timeliness of their appeal and the classification of their employment status – filed a petition, which led to a review by the Supreme Court.

Whether the CA erred in determining that petitioners’ appeal before the NLRC was filed out of time based on evidentiary documents (registry receipt, envelope date, and Laureta’s certification).
Whether the classification of petitioners as project employees by the CA was proper, or if they ought to be deemed regular employees entitled to due process and just cause for termination.
Whether the evidentiary basis, including the non-submission of employment contracts and the questionable credibility of the Barangay Rosario Certification, was sufficient to support project employment status or, alternatively, to establish regular employment.
Whether the NLRC’s ruling, which declared petitioners as regular employees and found illegal dismissal, was supported by substantial evidence and consistent with the applicable laws and jurisprudence.