Case Summary (G.R. No. 112535)
Employment Arrangement
The private respondents were initially hired as seasonal employees during peak business periods from September to January. Their employment ceased when the demand for their services declined. Following the 1988 CBA negotiations, these seasonal workers were transitioned into a different employment status referred to as "regular contractuals," which granted them benefits similar to regular employees, including security of tenure and minimum wage.
Nature of the Dispute
The respondents sought inclusion in the bargaining unit represented by the union alongside regular employees. However, the petitioner denied their inclusion, leading the respondents to file a complaint with the National Labor Relations Commission (NLRC) seeking recognition as regular employees with entitlements under the CBA.
Decision of the Labor Arbiter
The Labor Arbiter ruled in favor of the respondents, declaring them regular employees and entitled to all benefits provided in the CBA. This decision was affirmed by the NLRC in subsequent resolutions, rejecting the petitioner's appeal.
Petitioner's Legal Arguments
The petitioner contested the NLRC's findings, arguing that the private respondents did not qualify as regular employees prior to their "regularization" and were thus not entitled to the benefits under the CBA. The petitioner attempted to establish a distinction between "regular contractuals" and regular employees, disputing the automatic inclusion in the bargaining unit.
Applicable Law and Employment Classification
The legal basis for determining employment status is found in Article 280 of the Labor Code, which states that employees engaged in activities necessary to the employer's business shall be considered regular employees after rendering at least one year of service, regardless of employment type, unless specifically defined otherwise—such as seasonal work.
NLRC's Ruling on Employment Status
The NLRC upheld that the private respondents had indeed fulfilled the requirements for regular employment as outlined in Article 280. Since they each rendered over a year of service, they became entitled to the full suite of benefits afforded to regular employees under the CBA.
Jurisdictional Issues Raised by the Petitioner
The petitioner also argued that the complaints should be resolved through voluntary arbitration, as they involved the interpretation of the CBA. However,
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Case Background
- Petitioner, Cinderella Marketing Corporation, is duly organized and existing under Philippine law, with its principal office located in Quezon City.
- Private respondents in G.R. Nos. 112535 and 113758 are employees of the petitioner, categorized as "regular contractuals," performing various roles such as salesladies, wrappers, stockmen, and pressers.
- These employees are termed seasonal workers, hired during the peak season from September to January, with employment terminated after the peak demand subsides.
Employment Structure and Union Negotiations
- Prior to the 1988 Collective Bargaining Agreement (CBA) negotiations, the petitioner employed additional workers during peak seasons without a clear path to regularization.
- The Union's proposal during negotiations sought to regularize seasonal employees, resulting in an agreement that seasonal employees would be treated as regular contractuals with rights to benefits typically afforded to regular employees.
- Regular contractual employees would gain membership in the bargaining unit upon promotion or regularization, thus entitled to CBA benefits.
Employees' Claims and Labor Arbiter's Decision
- The private respondents expressed dissatisfaction with their exclusion from the bargaining unit and benefits, leading to a complaint filed with the Nat