Case Digest (G.R. No. 264439)
Facts:
Ramon O. Sampana v. The Maritime Training Center of the Philippines, G.R. No. 264439, February 26, 2024, Supreme Court Second Division, Lazaro-Javier, J., writing for the Court.Petitioner Ramon O. Sampana (Sampana) sued respondents The Maritime Training Center of the Philippines (TMTCP), Captain Alejandro C. Aquino, Jr. (CEO), and Normandy E. Gualberto (administration and finance manager) for illegal dismissal, regularization, and various monetary claims. Sampana alleges he was first engaged by TMTCP under a series of three-month “Consultancy Agreements” from March 21, 2011 to March 20, 2014, then under similarly worded three-month “Employment with a Fixed Term” contracts from March 21, 2014 until December 21, 2016. He asserts continuous service totaling over five years and that he asked TMTCP in November 2016 to grant optional retirement as he had reached age 60; he was allegedly dismissed on December 21, 2016 and required to sign a clearance and waiver the next day.
TMTCP answered that Sampana was a consultant and later a fixed-term employee engaged for discrete three-month training courses, that his contracts were voluntarily agreed and not vitiated by duress, and that the consultancy periods (2011–2014) do not create an employer-employee relationship and thus should be excluded from the five-year retirement computation. TMTCP also denied illegal dismissal, asserting nonrenewal due to trainees’ complaints about Sampana’s teaching.
Before the Court of Industrial Relations: the Labor Arbiter issued its Decision dated August 31, 2017 finding Sampana a regular employee and awarding retirement pay (PHP 116,775.00) while dismissing his other claims. On partial appeal, the National Labor Relations Commission (NLRC) reversed by Decision dated June 26, 2018, deleting the award of retirement pay for lack of legal and factual basis; Sampana’s motion for reconsideration before the NLRC was denied on September 26, 2018.
Sampana filed a petition for certiorari/appeal with the Court of Appeals, which affirmed the NLRC in a Decision dated March 18, 2021 and denied reconsideration by ...(Subscriber-Only)
Issues:
- Is Sampana a regular employee of TMTCP?
- Was Sampana illegally dismissed?
- Is Sampana entitled to backwages and retirement bene...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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