Case Summary (G.R. No. 200903)
Petition Details
Bajaro filed a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court, seeking to overturn the Court of Appeals (CA) Decision dated July 22, 2016, and Resolution dated October 27, 2016. The CA affirmed the National Labor Relations Commission (NLRC)'s ruling dismissing his complaint for illegal dismissal.
Background of Employment
Metro Stonerich Corporation is a domestic construction entity operated by Ibrahim M. NuAo. Bajaro was hired on June 4, 2008, and worked in various construction projects until May 10, 2014. His employment was characterized by a daily wage of Php 500 and was contingent on project completion.
Incident Leading to Dismissal
On April 21, 2014, while working at the KCC Mall of Marbel in Koronadal City, Bajaro experienced a leg injury. Following this, he sought medical treatment but was initially rebuffed by Metro Stonerich. He later recovered and returned to work on May 7, 2014, only to be informed that he should no longer report for work and was offered financial compensation instead.
Claims of Illegal Dismissal
Bajaro claimed regular employment status due to his continuous tenure over six years and asserted illegally dismissal when Metro Stonerich stopped his work without just cause. He also sought various monetary benefits arising from his employment.
Respondent's Argument
Metro Stonerich argued that Bajaro was a project employee engaged specifically for various construction projects with defined timelines. They maintained that his repeated rehiring did not grant him regular employee status and that he received all monetary benefits owed to him.
Ruling of the Labor Arbiter (LA)
On June 25, 2014, the LA ruled in favor of Metro Stonerich, declaring Bajaro a project employee based on the explicit terms of employment contracts. However, the LA awarded Bajaro an overtime pay differential and other benefits, while rejecting his claims for holiday pay and damages.
NLRC Decision
On July 30, 2015, the NLRC affirmed the LA's ruling, reinforcing that Bajaro's employment was project-based and validly terminated upon project completion. They found no violations of employment laws in Bajaro's classification.
CA Review
The CA upheld the NLRC's findings, emphasizing that Bajaro was properly classified as a project employee and that his employment status was fully disclosed at the time of hiring. The CA confirmed the monetary awards granted to Bajaro by the LA without finding any grave abuse of discretion.
Supreme Court Ruling
The Supreme Court dismissed Bajaro's petition, upholding the previous rulings regarding his employment classification. It clarified that the distinctions between regular and project employment are crucial, given the nature of the construction industry, where employment often fluctuates with project availability.
Employment Classification
The Court reiterated the definition of project employees under the Labor Code, which mandates that employees must be explicitly informed of their project-bound status. Bajaro’s documentation supported his classification as a project employee, thereby legitimizing his termination once the project was completed.
Conclusion on Employment Status
The Court concluded that the length of service and repeated rehiring in
...continue readingCase Syllabus (G.R. No. 200903)
Case Overview
- This case concerns the petition for review on certiorari filed by Mario Diesta Bajaro against Metro Stonerich Corp. and Ibrahim M. Nuao regarding the alleged illegal dismissal of Bajaro from his employment as a concrete pump operator.
- The case was decided by the Philippine Supreme Court on April 23, 2018, under G.R. No. 227982.
Background of the Case
- Bajaro was hired by Metro Stonerich on June 4, 2008, as a concrete pump operator and worked continuously until May 10, 2014, across various construction projects.
- His daily wage was Php 500.00, and he worked from 7:00 a.m. to 4:00 p.m., Monday through Saturday.
- On April 21, 2014, while working at KCC Mall of Marbel, Bajaro suffered an injury that hindered him from walking properly.
- Despite seeking medical assistance from Metro Stonerich, his requests for treatment were ignored, and he was sent home.
- After recovering from his injury, Bajaro was informed on May 8 and 9, 2014, that he should no longer report for work and was offered money instead, which he refused.
Legal Proceedings
- Bajaro filed a complaint for illegal dismissal against Metro Stonerich, asserting he was a regular employee entitled to security of tenure and various monetary benefits.
- Metro Stonerich argued that Bajaro was a project employee, hired specifically for five different projects with predetermined durations.
- The Labor Arbiter (LA) dismissed Bajaro's complaint for illegal dismissa