Case Digest (G.R. No. 195026)
Facts:
In Arlene T. Samonte, Vladimir P. Samonte, Ma. Aurea S. Elepano v. La Salle Greenhills, Inc., decided on February 10, 2016 under G.R. No. 199683, petitioners—three medical professionals who served as pediatricians and dentists in the Health Service Team (HST) of La Salle Greenhills, Inc. (LSGI) from 1989 to March 31, 2004—signed identical annual Contracts of Retainer expressly fixing their engagement from June 1 to March 31 of each school year. On March 31, 2004, LSGI informed them that their contracts would not be renewed because the school would hire full-time doctors. When petitioners sought separation pay, LSGI denied their claim. They filed for illegal dismissal before the NLRC, alleging they were regular employees entitled to security of tenure under the 1987 Constitution. The Labor Arbiter found them independent contractors and, as a matter of “compassionate social justice,” awarded half-month separation pay per year of service. On appeal, the NLRC corrected the classificCase Digest (G.R. No. 195026)
Facts:
- Employment of Petitioners
- From 1989 to March 31, 2004, petitioners Arlene T. Samonte, Vladimir P. Samonte, and Ma. Aurea S. Elepano served as medical professionals (pediatricians, dentists, physician) under La Salle Greenhills, Inc.’s (LSGI) Health Service Team (HST).
- Each academic year, they signed identical one-page “Contracts of Retainer” covering June 1 to March 31, stipulating: temporary character; automatic expiration; possible early termination for unsatisfactory performance or just cause; fixed rate of retainer fee.
- Termination and Procedural History
- At the end of the 2003–2004 school year, LSGI informed petitioners their contracts would not be renewed due to hiring full-time doctors; separation-pay requests were denied.
- Petitioners filed illegal dismissal complaints before the National Labor Relations Commission (NLRC), naming Bro. Bernard S. Oca as co-respondent.
- Labor Arbiter ruled petitioners were independent contractors, granted separation pay on compassionate grounds. NLRC modified this to fixed-term employees—no separation pay. Court of Appeals affirmed. Petitioners filed a Rule 45 petition for certiorari to the Supreme Court.
Issues:
- Whether the Court of Appeals erred in ruling petitioners were fixed-period employees and not regular employees of LSGI.
- Whether the Court of Appeals erred in not declaring petitioners illegally dismissed.
- Whether the Court of Appeals erred in not awarding reinstatement, backwages, separation pay, damages, and attorney’s fees.
- Whether the Court of Appeals erred in not holding respondents solidarily liable for acting in bad faith and with malice.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)