G.R. No. 241814 - Site for Eyes, Inc. vs. Dr. Amor Daming

Petitioner: Site for Eyes, Inc. (formerly Delos Reyes Optical City, Inc.), a domestic corporation engaged in dispensing optical lenses, solutions, and related equipment for its business operations.
Respondent: Dr. Amor F. Daming, a medical professional hired as an optometrist to provide essential diagnostic and prescription services.

November 20, 2012: The respondent was first hired as an optometrist for the petitioner’s shop at Ayala Centro Mall in Cagayan de Oro City.
October 15, 2013: Her initial stint of employment ended.
April 8, 2014: She was rehired under a one-year employment contract with a monthly salary of ₱28,000.00.
April 20, 2015: Her employment was renewed with a one-year contract promising an increased monthly salary of ₱33,000.00, although the promised ₱5,000.00 increase was not provided.

On March 22, 2016, the respondent, along with two co-employees, sought assistance before the Department of Labor and Employment under the Single Entry Approach (SEnA) to recover unpaid salary, salary differential, overtime pay, 13th month pay, separation pay, damages, attorney’s fees, and other costs.
An ensuing audit of the petitioner’s optical shops uncovered missing items.
During the SEnA hearing on April 20, 2016, the petitioner issued a show-cause notice to the respondent, threatening a lawsuit if she failed to account for the allegedly missing items.
The respondent accepted the notice on the condition that she be allowed to examine the store receipts pertinent to the audit; however, she was subsequently forbidden entry into the shop, a move that effectively terminated her employment.
As a result, the respondent filed a complaint for illegal dismissal with money claims.

Denied having granted the promised salary increase.
Asserted that even if a salary increase were granted, the respondent’s claim was barred by laches.
Contended that the respondent was employed under a fixed-term (yearly) contract, and her termination was merely the natural expiration of that fixed period, not a dismissal.

Presented text messages and employment contract documents evidencing the continuous renewal of her employment.
Argued that the contract contained provisions on duration, probationary status, and standards for regularization, thereby establishing her status as a regular employee.
Asserted that being barred from the shop amounted to constructive dismissal.

Found the respondent to be a regular employee based on her continuous engagement, notwithstanding the fixed-term contracts.
Determined that the petitioner’s act of barring the respondent from the shop amounted to a constructive dismissal.
Awarded monetary relief including full backwages, separation pay, unpaid salary, overtime pay, proportionate 13th month pay, wage differentials, and attorney’s fees.

Affirmed the Labor Arbiter’s findings, highlighting that the contracts of the years 2014 and 2015 were de facto employment contracts for regular employees.
Confirmed that the respondent had been illegally dismissed without just cause.

Upheld the findings of the Labor Arbiter and the NLRC, recognizing the four-fold test of the employer-employee relationship.
Affirmed the respondent’s status as a regular employee and the corresponding monetary awards based on her illegal (constructive) dismissal.

Petitioner filed the present petition challenging the previous rulings on three major issues (as later outlined in the Issues section), arguing errors in the findings on dismissal, employment status, and monetary awards.
Emphasis was placed on the interpretation of the fixed-term contractual arrangement and the alleged procedural and substantive errors committed by the NLRC and subsequently affirmed by the CA.

Whether the Court of Appeals erred in affirming the findings of the NLRC and the Labor Arbiter that the respondent was illegally and constructively dismissed, given that no valid constructive dismissal occurred and that the fixed-period employment contract was merely a mechanism to circumvent the law on regularization.
Whether the Court of Appeals erred in determining that the respondent was a regular employee despite her purported fixed-term employment status, noting that she did not raise her status as a fixed-term employee and that all elements of a valid fixed-term employment were allegedly present.
Whether the Court of Appeals erred in affirming the monetary awards, specifically the inclusion of backwages and separation pay, given that such awards were not among the reliefs initially prayed for by the respondent and are claimed to have no basis if there was no illegal dismissal.