Case Digest (G.R. No. 240774)
Facts:
- Toyo Seat Philippines Corporation (TSPC) and its president, Yoshihiro Takahama, are the petitioners.
- Respondents are Annabelle C. Velasco, Renato Natividad, Florante Bilasa, and Mary Ann Benigla.
- TSPC is engaged in manufacturing car seats and other automotive components.
- Respondents were hired as sewers for specific projects.
- Initially employed for Project J68C (Export Trim for 2008 Mazda 3 vehicle) starting in August 2008, estimated to be completed by September 2012.
- Due to a decline in demand, Project J68C ended early.
- Respondents were then employed for Project J68N (Export Trim for 2011 Mazda 3 vehicle) from June 8, 2011, to December 20, 2012.
- Due to low order volumes, respondents were also assigned to Project GS41 (Export Trim/Seats for Mitsubishi Lancer).
- Project J68N was extended until June 30, 2013, and further to July 12, 2013.
- Respondents declined the final extension, leading to their termination effective July 1, 2013.
- Respondents filed a complaint for regularization, which evolved into a complaint for illegal dismissal and non-payment of 13th month pay.
- The Labor Arbiter dismissed the complaint but ordered TSPC to pay the 13th month pay.
- The NLRC affirmed the Labor Arbiter's decision.
- The Court of Appeals reversed the NLRC's decision, ruling in favor of the respondents and ordering their reinstatement with backwages, moral and exemplary damages, and attorney's fees.
- TSPC filed a petition for review on certiorari with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the respondents were validly hired as project employees.
- The Court found that TSPC's project-based employment scheme did not circumvent the respondents' right to security of tenure.
- The absence of terminat...(Unlock)
Ratio:
- The Supreme Court emphasized that the determination of whether an employee is a project employee depends on whether they were hired for a specific project or undertaking, the completion or termination of which was determined at the time of their engagement.
- The Court found that the respondents' employment contracts clearly stated that their employment was coterminous with the actual duration of the projects.
- Respondents were not forced or coerced into signing these contracts.
- TSPC issued notices of extension for the J68N project, indicating that the projects had discrete and determinable start and end dates, adjusted based on economic factors such as consumer demand and the arrival of raw materials.
- The simultaneous engagement of respondents in the ...continue reading
Case Digest (G.R. No. 240774)
Facts:
The case involves Toyo Seat Philippines Corporation (TSPC) and its president, Yoshihiro Takahama, as petitioners, against respondents Annabelle C. Velasco, Renato Natividad, Florante Bilasa, and Mary Ann Benigla. TSPC, a company engaged in manufacturing car seats and other automotive components, hired the respondents as sewers for specific projects. Initially, respondents were employed for Project J68C (Export Trim for 2008 Mazda 3 vehicle) starting in August 2008, which was estimated to be completed by September 2012. However, due to a decline in demand, the project ended early, and respondents were subsequently employed for Project J68N (Export Trim for 2011 Mazda 3 vehicle) under a contract from June 8, 2011, to December 20, 2012. Due to low order volumes, respondents were also assigned to Project GS41 (Export Trim/Seats for Mitsubishi Lancer) to ensure they had work. The J68N project was extended until June 30, 2013, and then further extended to July 12, 2013, but respondents declined the final extension, leading to their termination effective July 1, 2013. Respondents filed a complaint for regularization, claiming they had attained regular employee status, which evolved into a complaint for illegal dismissal and non-payment of 13th month pay. The Labor Arbiter dismissed the complaint but ordered TSPC to pay the 13th month pay. The NLRC affirmed this decision, but the Court of Appeals reversed it, ruling in favor of the respondents and ordering their reinstatement with backwages, moral and exemplary damages, and attorney's fees. TSPC then filed a petition for review...