Case Digest (G.R. No. 184262) Core Legal Reasoning Model
Facts:
The case involves the University of Santo Tomas (UST) as the petitioner and the respondents Samahang Manggagawa ng UST and employees Fernando Pontesor, Rodrigo Clacer, Santiago Buisa, Jr., and Jimmy Nazareth. The respondents filed a complaint for regularization and illegal dismissal before the National Labor Relations Commission (NLRC), claiming that from 1990 to 1999, they were repeatedly hired by UST to perform maintenance duties such as laborer, mason, tinsmith, painter, electrician, welder, and carpenter. They argued that their performance of these vital tasks over the years entitled them to be considered regular employees with security of tenure. UST admitted to hiring them on a per-project basis, evidenced by numerous Contractual Employee Appointments (CEAs) that defined the terms and scopes of specific projects, which were renewable if incomplete but terminated upon project completion. The Labor Arbiter (LA) ruled in favor of the respondents, declaring them regular emplo
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Case Digest (G.R. No. 184262) Expanded Legal Reasoning Model
Facts:
- Parties Involved
- Petitioner: University of Santo Tomas (UST)
- Respondents: Samahang Manggagawa ng UST and employees Fernando Pontesor, Rodrigo Clacer, Santiago Buisa, Jr., and Jimmy Nazareth (collectively referred to as Pontesor, et al.)
- Nature of Complaint
- Respondents filed a complaint for regularization and illegal dismissal before the National Labor Relations Commission (NLRC).
- They alleged that from 1990 to 1999, they were repeatedly hired by UST as laborers performing various maintenance duties (mason, tinsmith, painter, electrician, welder, carpenter).
- Respondents contended that their continuous work for the petitioner constituted regular employment and that their dismissal was illegal.
- Petitioner’s Position
- Petitioner admitted the respondents were repeatedly hired but argued they were hired on a per-project basis under numerous Contractual Employee Appointments (CEAs).
- Each CEA specified the nature and term of a project; employment terminated automatically when project ended or upon expiration of the specified term.
- Petitioner maintained that the termination was lawful due to completion of projects.
- Labor Arbiter’s (LA) Decision (October 23, 2002)
- Declared respondents as regular employees of petitioner.
- Found that respondents rendered at least one year of service each, performed work vital or inherently indispensable to petitioner’s operations, and that CEAs were contrived to avoid regularization.
- Ordered reinstatement with backwages and no loss of seniority.
- NLRC’s Rulings
- March 26, 2004 Resolution vacated LA decision and dismissed respondents’ complaint for lack of merit.
- Held respondents were fixed-term casual employees due to voluntary entry into fixed-term contracts.
- Rejected petitioner’s claim of project employees, concluding the work was neither necessary nor desirable to petitioner’s main business (providing education).
- Denied respondents’ motion for reconsideration on May 25, 2004.
- Court of Appeals (CA) Decision (June 12, 2008)
- Reversed and set aside the NLRC ruling, reinstating the LA decision.
- Determined respondents were regular employees entitled to security of tenure because:
- They performed work necessary and desirable to petitioner’s business, evidenced by repeated rehiring and continuous need.
- Project descriptions in CEAs were vague and broad, indicating no definite project or undertaking.
- Denied petitioner’s motion for reconsideration on August 22, 2008.
- Petition before the Supreme Court
- Petitioner filed a petition for review on certiorari questioning the CA’s ruling classifying respondents as regular employees and holding their dismissal illegal.
Issues:
- Whether the Court of Appeals correctly ruled that respondents were regular employees of petitioner.
- Whether respondents’ dismissal by petitioner was illegal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)