Case Summary (G.R. No. 218009)
Background Facts
Felipe and Velasco were employed by DDTKI in different capacities, with Felipe starting as a Formworks Aide on December 19, 2005, and Velasco as a Warehouse Aide on March 14, 2007. They asserted that they maintained regular employment status until September 2010, when they were not assigned any further work. They sought clarification regarding their employment status through a letter dated September 28, 2010, but received no response. Subsequently, on October 12, 2010, they lodged a complaint for illegal dismissal and non-payment of benefits with the arbitration branch of the National Labor Relations Commission (NLRC).
Respondents' Claim
In response, DDTKI contended that both Felipe and Velasco were project employees, hired specifically for designated projects with defined durations. They produced employment contracts argued to corroborate that the petitioners were aware of the temporary nature of their employment. The company indicated that once the projects were completed, they did not have further need for their services and hence reported their termination to the Department of Labor and Employment (DOLE) as a completion of work phase.
Labor Arbiter's Decision
On March 28, 2011, the Labor Arbiter issued a decision dismissing the complaint, asserting that Felipe and Velasco were indeed project employees as shown by the nature of their contracts. The Arbiter emphasized that contracts specified the duration of employment tied to specific projects, indicating lawful termination upon project completion.
National Labor Relations Commission Ruling
The NLRC upheld the Labor Arbiter's decision, concluding that the termination was legitimate due to the expiration of the project employment contracts. However, a modification required DDTKI to compensate the petitioners for their proportionate 13th-month pay. Following a motion for reconsideration by petitioners which was denied, they escalated their case to the Court of Appeals (CA).
Court of Appeals Decision
The CA denied the petition after examining the findings of the NLRC, affirming that the petitioners' continuous service did not qualify them as regular employees since their employment was limited to defined projects. The CA ruled that the internal memo (Manpower Requisition Form) presented by petitioners did not constitute a basis for regular employment.
Issues Raised by Petitioners
Petitioners raised three main issues: their classification as regular employees, claims of illegal dismissal, and entitlements to monetary claims including damages and attorney's fees. They argued against the CA's determination, asserting a lack of project documentation justifying their classification as project employees while emphasizing their significant tenure.
Respondents' Position
Respondents contended that the petitioners failed to demonstrate that the CA acted with grave abuse of discretion in its rulings. They maintained that the absence of a continuous employment relationship, juxtaposed with the project-based nature of their roles, substantiated their decision not to renew contracts post-project completion.
Supreme Court's Ruling
The Supreme Court acknowledged that the matter c
...continue readingCase Syllabus (G.R. No. 218009)
Case Overview
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioners, Marvin G. Felipe and Reynante L. Velasco, challenge the March 27, 2013 Decision and March 26, 2015 Resolution of the Court of Appeals (CA).
- The CA affirmed the September 30, 2011 Decision and December 7, 2011 Resolution of the National Labor Relations Commission (NLRC) regarding the illegal dismissal complaint filed by the petitioners.
Antecedents
- Felipe was hired as a Formworks Aide on December 19, 2005, while Velasco was hired as a Warehouse Aide on March 14, 2007.
- Both claimed regular employment status due to continuous work until September 2010, when they were no longer assigned tasks.
- They inquired about their employment status via a letter dated September 28, 2010, regarding their non-transfer to the Glorietta Project, which was set to begin on September 17, 2010. The respondents did not respond.
- On October 12, 2010, they filed a complaint for illegal dismissal, non-payment of service incentive leave, and 13th month pay before the NLRC.
Respondents' Position
- DDTKI and Tamayo argued that petitioners were project employees hired for specific projects, supported by signed employment contracts.
- They asserted that Felipe and Velasco were not rehired post-project completion, claiming their termination was reported to the Department of Labor and Employment (DOLE) as completion of work.
- The respondents maintained that the document in question (Manpower