Case Digest (G.R. No. 96078) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Hilario Rada v. National Labor Relations Commission (Second Division) and Philnor Consultants and Planners, Inc. (G.R. No. 96078, January 9, 1992), petitioner Rada was engaged as a driver under a series of successive “Contract[s] of Employment for a Definite Period” with Philnor for the Manila North Expressway Extension, Second Stage (MNEE Stage 2) project. His first contract covered July 1, 1977 to June 30, 1979; a second spanned July 1, 1979 to April 30, 1980; a third ran May 1, 1980 to November 30, 1981; and subsequent extensions ultimately expired on December 31, 1985. Each written agreement stipulated that his services would terminate automatically upon completion of the project phase. In December 1985 Rada executed a release and received cash conversion of leave credits. On May 20, 1987 he filed before the NLRC a complaint for separation pay, reinstatement with backwages, and overtime compensation. The labor arbiter ruled on August 31, 1989 that Rada was a regular emplo Case Digest (G.R. No. 96078) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment Engagements
- Petitioner Hilario Rada was hired by Philnor Consultants and Planners, Inc. as a driver under successive fixed‐term contracts for the Manila North Expressway Extension, Second Stage (MNEE Stage 2) project:
- First contract: July 1, 1977 to June 30, 1979 (24 months)
- Second contract: July 1, 1979 to April 30, 1980 (10 months)
- Third contract: May 1, 1980 to November 30, 1981 (19 months), with subsequent extensions up to December 31, 1985
- All contracts expressly stated employment was co‐terminus with the specified project phase and would automatically terminate upon completion.
- Termination and Post‐Contract Actions
- The last contract extension (October 1, 1985 to December 31, 1985) was not renewed due to project completion.
- In December 1985, petitioner applied for personnel clearance, received cash conversion of unused leave credits and financial assistance (₱3,796.20), and executed a Release, Waiver and Quitclaim.
- Administrative Proceedings
- May 20, 1987: Petitioner filed before NLRC a complaint for non‐payment of separation pay and overtime pay.
- Philnor’s defense: Petitioner was a project employee; no illegal dismissal; no overtime work; executed quitclaim.
- July 1987: Petitioner amended complaint, claimed illegal dismissal as a regular employee and entitlement to overtime pay.
- August 31, 1989: Labor Arbiter ordered reinstatement with backwages and awarded overtime pay for three excess hours daily from January 1983 to December 1985.
- November 19, 1990: NLRC reversed the arbiter’s decision, dismissed the complaint, and held petitioner was a project employee.
- Petitioner filed a petition for certiorari with the Supreme Court challenging the NLRC decision.
Issues:
- Jurisdictional Question
- Whether NLRC had jurisdiction to entertain Philnor’s appeal despite late filing of the supersedeas bond.
- Employee Status and Security of Tenure
- Whether petitioner, after nearly eight years of continuous service under consecutive fixed‐term contracts, attained the status of a regular employee with security of tenure.
- Whether his termination upon project completion amounted to illegal dismissal.
- Entitlement to Benefits
- Whether petitioner was entitled to separation pay or reinstatement with backwages.
- Whether petitioner was entitled to overtime pay for three hours daily spent in transporting employees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)