Case Summary (G.R. No. 194467)
Chronology of Events
The petition follows a series of decisions beginning with a Labor Arbiter's ruling on December 15, 1994, which recognized the petitioners as regular employees of San Miguel Corporation, having been previously employed through a labor-only contractor, Lippercon Services, Inc. The decision ordered their reinstatement and awarded backwages. An appeal by San Miguel Corporation was made, resulting in modifications regarding backwages and separation pay until a subsequent compromise was reached.
Labor Arbitration and Compromise
During the execution of the reinstatement order, the petitioners entered into a compromise agreement, settling their claims for P550,000 each, which included their money claims related to illegal dismissal. The compromise was finalized on June 25, 2003, and reinstatement was scheduled for July 1, 2003. However, upon reinstatement, San Miguel reckoned their length of service from the date of reinstatement rather than their initial dates of employment.
Dispute Over Service Length Reckoning
The core issue is the reckoning date for the petitioners’ length of service—whether it should be the date they were reinstated or the date they initially commenced their roles in 1985 and 1988, respectively. The petitioners argued that reinstatement should not reset their service length while San Miguel contended that their previous employment was terminated, thus making them new hires.
Voluntary Arbitration Decision
Voluntary Arbitrator Angel A. Ancheta ruled in favor of the petitioners, determining that their length of service should indeed be counted from their original hiring dates based on the interpretation of reinstatement, which indicates returning to a state of employment that had been interrupted through illegal dismissal.
Court of Appeals' Ruling
The Court of Appeals later modified the voluntary arbitrator's decision, maintaining that the length of service should be reckoned from the declaration as regular employees on December 15, 1994. They justified this by stating the petitioners began employment under a contractor arrangement and needed formal declaration as regular employees before claiming any additional length of service rights.
Supreme Court's Analysis
The Supreme Court emphasized that reinstated employees are not considered new hires and that their service is continuous if the prior employment was ended through illegal dismissal. As such, they ruled that the length of service for Melchor should be reckoned from 1985 and for Melencio and Serafin from 1988. The execution of the quitclaims did not negate their previous employment histo
...continue readingCase Syllabus (G.R. No. 194467)
Case Background
- The case involves a Petition for Review on Certiorari filed by Melchor A. Cuadra, Melencio Trinidad, and Serafin Trinidad against San Miguel Corporation.
- The primary issue centers on the reckoning date of the petitioners' length of service with San Miguel Corporation, particularly after their illegal dismissal and subsequent reinstatement.
Procedural History
- The petitioners were among 60 complainants who filed an illegal dismissal case on January 4, 1991, against Lippercon Services, Inc. and San Miguel Corporation.
- During the proceedings, 51 complainants reached an amicable settlement.
- Labor Arbiter Manuel R. Caday issued a decision on December 15, 1994, declaring the remaining nine complainants as regular employees and found that Lippercon Services was a "labor-only" contractor.
- San Miguel appealed the decision to the National Labor Relations Commission (NLRC), which modified the ruling to mandate separation pay instead of reinstatement.
Court of Appeals Rulings
- The Court of Appeals affirmed the NLRC's decision on April 12, 1999, with modifications concerning back wages.
- Subsequent motions for reconsideration were filed by both parties, resulting in an October 14, 1999, resolution that reinstated the petitioners while denying San Miguel's motion for reconsideration.
Compromise Agreement and Reinstatement
- On September 1, 2000, a Writ of