Case Summary (G.R. No. 78693)
Applicable Law
The 1987 Philippine Constitution and the Labor Code of the Philippines apply to this case, particularly regarding employment status and the rights of employees.
Factual Background
Zosimo Cielo was engaged in a six-month contract with Henry Lei Trucking Company, which was set to commence on June 30, 1984, and ended on December 31, 1984. Cielo contended that following this period, he had acquired the status of a regular employee due to his continuous service, thereby claiming entitlement to protections against dismissal except for lawful causes.
Employment Termination and Legal Proceedings
On December 22, 1984, Cielo received notice of his termination supported by the argument that his employment had expired as per the contract. Cielo contested this decision, asserting that he was, in fact, a regular employee with rights protected under the Labor Code, and he filed a complaint with the Ministry of Labor and Employment on January 22, 1985.
Arguments from Both Parties
Henry Lei Trucking Company maintained that the agreement governing Cielo's employment clearly defined it as contractual, with no employer/employee relationship. The company argued that it was within its rights to terminate Cielo's employment once the contract expired. In contrast, Cielo argued that the nature of the employment and the company’s policies were designed to circumvent the protections afforded to employees under the Labor Code.
Contractual Agreement Analysis
The court examined the contractual agreement, which was explicit in stating that the relationship was non-employer-employee. However, it also analyzed the affidavit required by the company, which suggested otherwise by indicating that Cielo had received salary and allowances from Henry Lei. This contradiction raised questions about the true nature of the relationship and reflected an attempt by the respondent to evade the applicable labor laws.
Legal Determinations
The Court concluded that Zosimo Cielo should be regarded as a regular employee, protected by labor laws, since his duties were central to the respondent's trucking business—an operation that could not be classified as merely project-based or seasonal. The contract was deemed tantamount to a circumvention of statutory rights, and thus it was null and void.
Ruling on Employment Status and Rights
The ruling emphasized the importance of security of tenure as enshrined in labor legislation. The Court held that contracts designed to circumvent employee rights cannot be upheld, reinforcing the notion that repeated short-term contracts intended to prevent regulariz
...continue readingCase Syllabus (G.R. No. 78693)
Case Background
- The petitioner, Zosimo Cielo, is a truck driver who alleges illegal dismissal by Henry Lei Trucking Company.
- The Labor Arbiter ruled in favor of Cielo, ordering his reinstatement with back wages.
- The decision was appealed to the National Labor Relations Commission (NLRC), which reversed the ruling, stating that Cielo's employment had expired under a valid contract.
Legal Proceedings
- Cielo filed a petition for certiorari under Rule 65 of the Rules of Court after the NLRC's decision.
- The private respondent filed a motion to dismiss the petition, arguing it was late by sixty-eight days.
- The motion was dismissed as the Court allows petitions under Rule 65 to be filed within a reasonable period, generally three months.
Contractual Agreement
- An agreement was presented that outlined the relationship between Cielo (the second party) and Henry Lei (the first party).
- The agreement specified:
- A six-month term of employment with provisions for early termination.
- A profit-sharing scheme where net income was divided on a 90/10% basis in favor of Henry Lei.
- Explicitly stated that there was no employer-employee relationship between the parties.
Termination of Employment
- Cielo was notified of the termination of his services on December 22, 1984, based on the expiration of the contract.
- Cielo contested th