G.R. No. 172927 - Sorreda vs. Cambridge Electronics Corporation

Petitioner Ronilo Sorreda was hired by respondent Cambridge Electronics Corporation on May 8, 1999, as a technician for a specific project under a fixed five‐month contract at minimum wage.
Five weeks into his employment, on June 15, 1999, petitioner suffered a severe accident in which his left arm was crushed by a machine, necessitating an amputation.

Shortly after his release from the hospital, petitioner was summoned to a meeting by company officers. Present at the meeting were his common-law wife, father, and cousin, during which he was verbally assured a position as a regular employee—i.e., that he would be employed for as long as the company existed—once he had fully recovered from his injury.
In September 1999, after recovering from his injuries, petitioner reported for work expecting to be reinstated, only to be made to sign a memorandum of resignation, which formalized his separation from the company on the basis that his five‐month employment contract had expired.

On November 16, 1999, petitioner filed a complaint in the Regional Arbitration Branch of the NLRC of Dasmariñas, Cavite. Initially, the complaint was for illegal dismissal; later, petitioner changed it to a claim for breach of contract.
In his position paper, petitioner raised issues regarding the existence of a valid, perpetual contract of employment—arguing that there was an implied agreement which promised him regular employment—and sought compensatory, moral, exemplary damages, and attorney’s fees as a remedy for respondent’s alleged breach.

The labor arbiter, relying on the positive declarations of the witnesses (petitioner’s common-law wife, father, and cousin) and applying the parole evidence rule, ruled that petitioner had effectively become a regular employee by virtue of the alleged contract of perpetual employment. He ordered petitioner’s reinstatement, along with backwages, moral damages, exemplary damages, and attorney’s fees.
Both petitioner and respondent subsequently appealed to the NLRC. The NLRC reversed the labor arbiter’s ruling, finding that petitioner was not a regular employee because he was employed strictly on a per-project basis; accordingly, petitioner was neither illegally dismissed nor entitled to reinstatement and backwages.

Petitioner then filed a petition for certiorari before the Court of Appeals, challenging the NLRC’s finding that the contract of perpetual employment did not exist.
The Court of Appeals dismissed the petition, holding that the labor arbiter erroneously assumed jurisdiction over a dispute involving an alleged second, separate contract of perpetual employment, which was not rooted in the employer-employee relationship created by the original five‐month contract. It further noted that claims for breach of such a contract were within the exclusive jurisdiction of the regular courts.

Whether a valid and enforceable contract of perpetual employment—implying regular employee status—was ever perfected between petitioner and respondent.
If such a contract existed, whether it legally converted petitioner’s status from a per-project employee to that of a regular employee.

Whether the labor arbiter had proper jurisdiction to adjudicate petitioner’s claim based on an alleged breach of a separate contract, which entailed issues inherently civil in nature and not directly arising from the employer-employee relationship established under the per-project contract.
Whether the dispute over the alleged perpetual employment falls within the ambit of labor courts or should be heard by regular courts.

Whether the witness testimonies (from petitioner’s common-law wife, father, and cousin) and the admissibility of parole evidence were sufficient to establish the existence of the purported contract of perpetual employment.
Whether such evidentiary submissions could justify a reclassification of petitioner’s employment status and warrant the reliefs claimed.