Title
Hacienda Fatima vs. National Federation of Sugarcane Workers-Food and General Trade
Case
G.R. No. 149440
Decision Date
Jan 28, 2003
A labor dispute over illegal dismissal and unfair labor practices, where seasonal workers were deemed regular employees due to repeated hiring, with the Supreme Court affirming reinstatement, backwages, and damages for union-related violations.

Case Summary (G.R. No. 149440)

Key Dates and Procedural Posture

Lower proceedings: labor complaint filed with Labor Arbiter; NLRC rendered decision finding illegal dismissal and unfair labor practice; CA (Eighth Division) denied petition for certiorari and affirmed NLRC; Supreme Court review by certiorari under Rule 45 (G.R. No. 149440) culminating in the challenged Supreme Court decision.

Applicable Law

Primary statutory provision applied: Article 280, Labor Code (Regular and Casual Employment) as amended. Procedural law: Rule 45, Rules of Court (petition for review on certiorari). Doctrinal principles: distinction between seasonal and regular employment, test for regular employment (connection of the activity to employer’s usual business and continuity/repeated need), and standards governing unfair labor practices and remedies (reinstatement, backwages, moral and exemplary damages).

Factual Summary — Employment Relationship and Collective Action

Respondents were sugarcane workers who performed seasonal agricultural tasks for petitioners. The record shows that, except for four named individuals (Luisa Rombo, Ramona Rombo, Bobong Abriga and Boboy Silva), the workers repeatedly performed the same tasks for petitioners across several seasons and over several years. After union certification and attempts to bargain collectively, petitioners allegedly refused to bargain, used economic inducements, promoted non‑union workers, employed private guards to prevent organizers’ entry, and failed to give work assignments to union members beginning September 1991. These events led to strikes and the execution of memoranda of agreement and conciliation minutes that contemplated lists, payroll references, and a committee to determine the status of 36 union members.

Agreements, Conciliation and Subsequent Events

Two memoranda of agreement and a conciliation meeting produced commitments by management (e.g., priority in assignments to union women workers, reinstatement of specific workers, provision of wagons, exclusion of scabs) and procedures to determine the status of the listed workers using the 1990 payroll and other references. Minutes of the conciliation meeting identified specific employees for immediate reinstatement upon availability of work and excluded the four individuals noted above. Petitioners allegedly reneged on commitments, did not provide assigned work, and hired others to perform tasks previously performed by union members.

Issues Presented to the Supreme Court

A. Whether respondents, although performing seasonal work, are regular employees under Article 280 of the Labor Code (i.e., whether their employment extended beyond “the duration of the season”). B. Whether the CA erred in its reliance on precedents distinguishing seasonal from regular employment, and whether Mercado v. NLRC was controlling. C. Whether CA and NLRC committed grave abuse in finding illegal dismissal, unfair labor practice, and in awarding reinstatement, backwages, and moral and exemplary damages.

Standard of Review and Treatment of Findings of Fact

The Supreme Court reiterated that only errors of law are generally reviewable in Rule 45 petitions from CA decisions; factual findings of labor tribunals are accorded great weight and are not ordinarily disturbed unless shown to be arbitrary or unsupported by any rational basis. In labor cases, deference to the NLRC and to labor officials’ specialized findings is particularly strong.

Legal Analysis — Regular vs. Seasonal Employment

Article 280 provides that employment is regular when the employee performs activities usually necessary or desirable in the employer’s usual business, except where the engagement is for a specific project or for seasonal work limited to the duration of the season. The Court emphasized that two conditions must be met to classify seasonal workers as excluded from regular status: (1) the work must be seasonal in nature; and (2) the employment must be only for the duration of one particular season. In this case, while the nature of the work was seasonal, the second condition was not satisfied because the respondents (except the four excluded individuals) repeatedly worked for petitioners across several seasons and years. Repeated seasonal engagement for the same tasks establishes a continuing need and renders the employment regular with respect to those activities. The Court relied on prior jurisprudence (e.g., De Leon and Abasolo) explaining that intermittently called seasonal workers who are repeatedly reengaged are considered on leave during off‑seasons rather than separated from employment.

Application of Precedent — Mercado and Distinctions

The Court distinguished Mercado v. NLRC on its facts: in Mercado the workers were hired for definite phases and were available to be employed by any farm owner after that phase, and they were not repeatedly hired by the same employer for the same phase over successive seasons. By contrast, the respondents in this case were repeatedly employed by petitioners for the same seasonal tasks over several years; thus Mercado did not control. The CA’s reliance on other precedents addressing repeated seasonal employment was held appropriate.

Illegal Dismissal Analysis

Because the respondents were regular employees with security of tenure, petitioners’ cessation of work assignments to union members and hiring of replacements constituted a termination of employment. Petitioners failed to prove clear, valid and lawful cause for the termination. The Court found that changes in assignments implemented immediately after union organization and bargaining demands indicated bad faith. Where an employer does not establish lawful cause for termination, the termination constitutes illegal dismissal; the burden to justify the dismissal rests on the employer.

Unfair Labor Practice Findings and Remedies

The NLRC found, and t

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