Case Digest (G.R. No. 264439) Core Legal Reasoning Model
Facts:
Ramon O. Sampana, petitioner, filed a complaint on April 11, 2017, against The Maritime Training Center of the Philippines (TMTCP), Captain Alejandro C. Aquino, Jr., and Normandy E. Gualberto for illegal dismissal, regularization, and payment of retirement and other benefits. Sampana was initially hired by TMTCP as an Instructor under a consultancy agreement from March 21, 2011, to June 21, 2011, with a monthly salary of PHP 25,000. This consultancy agreement was repeatedly renewed every three months for three years until March 20, 2014. Afterwards, his contract was changed to "Employment with a Fixed Term" for three-month periods, repeatedly renewed until December 21, 2016, with a monthly gross compensation of PHP 27,000. Sampana sent letters in November 2016 expressing his intent to retire after serving five years and eight months and inquiring about his retirement benefits. On December 21, 2016, he was dismissed allegedly without just cause and was made to sign a c
Case Digest (G.R. No. 264439) Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioner Ramon O. Sampana was employed by The Maritime Training Center of the Philippines (TMTCP), an educational institution providing training to Filipino seafarers.
- Respondents include TMTCP, Captain Alejandro C. Aquino Jr. (CEO), and Normandy E. Gualberto (Admin and Finance Manager).
- Sampana filed a complaint on April 11, 2017 for illegal dismissal, regularization, and benefits including retirement pay and 14th month pay.
- Employment History
- Initially hired as a consultant for three months from March 21, 2011 to June 21, 2011, with continuous renewals every three months for three years (until March 20, 2014), paid PHP 25,000 monthly.
- Contract changed to "Employment with a Fixed Term" from March 21, 2014 to June 21, 2014, renewed every three months until December 21, 2016, with PHP 27,000 monthly compensation.
- Events Leading to Complaint
- Sampana sent letters on November 8, 2016 and November 24, 2016, expressing intent to retire after serving five years and inquiring about retirement benefits.
- On December 21, 2016, Sampana was dismissed without just cause and was asked to sign a clearance form releasing claims.
- Respondents' Position
- TMTCP asserted that Sampana was initially a consultant, later a fixed-term employee, employed only for the three-month duration of training courses.
- Non-renewal was due to complaints about Sampana's teaching methods; thus, no illegal dismissal occurred.
- Sampana was not entitled to retirement pay as he did not meet five years' service requirement; consultancy period excluded.
- 14th month pay is a management prerogative; thus, Sampana's claims dismissed.
- Labor Arbiter's Decision (August 31, 2017)
- Sampana was a regular employee under Article 280 of the Labor Code.
- Awarded retirement pay of PHP 116,775 based on 5 years' service.
- Illegal dismissal claim denied as Sampana had opted to retire.
- Claims for 14th month pay and training fees denied.
- National Labor Relations Commission (NLRC)
- On June 26, 2018, NLRC reversed labor arbiter's award of retirement pay, holding that Sampana was a fixed-term employee from March 21, 2014 to December 21, 2016.
- Consultancy period excluded from computation as no employer-employee relationship existed.
- Motion for reconsideration denied on September 26, 2018.
- Court of Appeals (CA)
- On March 18, 2021, affirmed NLRC decision denying retirement pay.
- Sampana's motion for reconsideration denied October 20, 2022.
- Present Petition
- Sampana claims he was a regular employee continuously employed for over 5 years under similar contracts.
- Argues fixed-term contracts were a scheme to deny security of tenure and benefits.
Issues:
- Whether Sampana is a regular employee of TMTCP.
- Whether Sampana was illegally dismissed.
- Whether Sampana is entitled to backwages and retirement benefits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)