Case Digest (G.R. No. L-25176) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Universal Robina Sugar Milling Corporation v. Acibo (G.R. No. 186439, January 15, 2014), petitioners Universal Robina Sugar Milling Corporation (URSUMCO) and its Business Unit General Manager Rene Cabati challenged the Court of Appeals’ affirmance, with modification, of the National Labor Relations Commission’s reversal of the Labor Arbiter’s dismissal of respondents’ complaints. Respondents Ferdinand Acibo, et al., twenty-two seasonal workers hired between February 1988 and April 1996 as drivers, crane operators, welders, mechanics, laboratory attendants and other mill personnel, executed successive one-month or seasonal contracts with URSUMCO. On August 23, 2002, seven of them appealed the Labor Arbiter’s October 9, 2002 dismissal of their petition for regularization and entitlement to Collective Bargaining Agreement (CBA) benefits. On July 22, 2005, the NLRC declared them regular employees entitled to CBA benefits, a ruling denied reconsideration on April 28, 2006. The CA, Case Digest (G.R. No. L-25176) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Petitioners: Universal Robina Sugar Milling Corporation (URSUMCO) and its Business Unit General Manager, Rene Cabati.
- Respondents: Twenty-two (22) workers (drivers, crane operators, welders, laborers, etc.) hired between February 1988 and April 1996 under one-month or seasonal contracts for sugar-milling tasks.
- August 23, 2002 – Respondents filed before the Labor Arbiter (LA) complaints for regularization, CBA benefits, and attorney’s fees.
- October 9, 2002 – LA dismissed the complaints, holding respondents were project/seasonal workers coterminous with specific milling phases.
- July 22, 2005 – NLRC reversed LA, declared complainants regular employees under Article 280, Labor Code, and awarded CBA benefits; April 28, 2006 – NLRC denied reconsideration.
- November 29, 2007 – CA partially granted URSUMCO’s certiorari petition: affirmed regular status but denied CBA benefits; January 22, 2009 – CA denied motion for partial reconsideration.
- March 18, 2009 – Petition for review on certiorari filed before the Supreme Court under Rule 45.
- Nature of Employment
- Respondents rehired seasonally or monthly to perform recurring tasks (hauling cane, operating equipment, mill maintenance) essential to URSUMCO’s milling operations.
- Contracts specified fixed durations tied to each milling season; no documented proof respondents could work elsewhere during off-season.
Issues:
- Employment Status
- Are respondents regular employees of URSUMCO under Article 280 of the Labor Code?
- Alternatively, are they project, seasonal, or casual workers without entitlement to security of tenure and CBA benefits?
- Relief for Non-Appealing Complainants
- Can affirmative relief be extended to the fifteen (15) complainants who did not appeal the LA decision?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)