Case Summary (G.R. No. 195513)
Employment Dynamics and Alleged Dismissal
Petitioners were employed under fixed-term contracts as merchandisers for APMC, specifically for Delfi Marketing, Inc. A notice from Delfi indicated the expiration of their promotional contract with APMC, leading to APMC's notification to petitioners regarding the termination of their employment effective January 30, 2007. This situation prompted petitioners to file separate complaints for illegal dismissal and related money claims.
Proceedings Before the Labor Arbiter
In the consolidated complaints against APMC, petitioners argued their status as regular employees, claiming entitlement to security of tenure and illegal dismissal due to the promotional contract's expiration. They maintained that new employees were being hired for their previous positions, contradicting APMC's claim of lawful termination.
Labor Arbiter's Decision
The Labor Arbiter ruled in favor of the petitioners, stating that APMC failed to prove the contractual nature of their employment and illegally dismissed them. The decision mandated reinstatement or separation pay, back wages, and various damages.
Appeal to the National Labor Relations Commission (NLRC)
Respondents appealed the Labor Arbiter's decision, asserting petitioners were contractual employees and dismissing the argument of illegal termination based on the contract's expiration. They contested the monetary awards and bond requirements, seeking reductions based on procedural issues in the original complaint.
NLRC's Ruling
The NLRC sided with the respondents, reversing the Labor Arbiter's ruling. It declared that the petitioners were indeed hired as contractual employees and their employment was automatically terminated upon the promotional contract's expiration. Although the NLRC dismissed the illegal dismissal claims, it directed payment of certain unpaid wages, affirming partial benefits for petitioners.
Court of Appeals' Decision
The Court of Appeals rejected the petitioners’ certiorari petition, asserting that the NLRC acted within its jurisdiction while granting the appeal despite the contested bond issues. The CA upheld the findings that petitioners were not illegally dismissed, referencing the fixed-term nature of their contracts and the clear indication of voluntary acceptance of employment terms.
Legal Issues on Appeal
Several legal issues were raised: whether the appeal with a motion to reduce the bond tolls the period for perfecting an appeal; the adequacy of the bond, given the monetary award; the finality of the Labor Arbiter’s decision; and whether adjudication was correct in light of pending motions.
Court's Ruling on Procedural Matters
The ruling confirmed that failure to post a sufficient bond does not prevent the perfecting of an appeal if a meritorious motion to reduce has been filed along with a reasonab
...continue readingCase Syllabus (G.R. No. 195513)
Procedural Background
- This case involves a Petition for Review on Certiorari challenging the November 30, 2010 Decision of the Court of Appeals (CA) in CA-G.R. SP No. 111536.
- The CA's decision affirmed the February 23, 2009 Decision and August 4, 2009 Resolution of the National Labor Relations Commission (NLRC), which reversed the Labor Arbiter’s ruling declaring the petitioners as illegally dismissed employees.
- The petitioners contest the CA's decisions, including the denial of their Motion for Reconsideration on February 3, 2011.
Antecedent Facts
- Ace Promotion and Marketing Corporation (APMC) is a contractor led by Glen Hernandez, engaged in deploying workers for marketing and merchandising services.
- APMC entered into a Promotional Contract with Delfi Marketing, Inc. for promoting confectionery products, employing the petitioners under fixed-term contracts.
- The last employment contracts of petitioners were set to expire on January 30, 2007, with a notice from Delfi on December 27, 2006, stating the expiration of their contract.
Proceedings Before the Labor Arbiter
- Petitioners filed complaints for illegal dismissal and money claims against APMC and Delfi, arguing they were regular employees and that the termination was due to the expiration of the contract, which they claimed did not automatically lead to dismissal.
- Respondents asserted that the petitioners were contractual employees, and their employment ended with the expiration of the Promotional Contract.
- The Labor Arbiter ruled in favor of the petitioners on April 24, 2008, declaring their dismissal illegal, ordering reinstatement or separation pay, backwages, unpaid wages, ECOLA, moral and exe