Case Summary (G.R. No. 106654)
Employment History
Rodolfo Peronila was employed as a driver by Pantranco North Express, Inc. in 1971 and faced an administrative investigation in 1973 due to absences without leave spanning over two months. The investigation concluded with the corporation dismissing him for violating company policies, with the dismissal being affirmed by NLRC's Mediator-Factfinder in March 1973.
Reemployment and Contractual Agreement
Fifteen years after his dismissal, Peronila requested to be rehired, which Pantranco initially denied. However, they later hired him on a fixed-term contract on April 5, 1988, for one month, which outlined a clear absence of an employer-employee relationship, thereby excluding him from employee benefits such as sick leave or overtime pay.
Termination of Employment
On April 20, 1988, just fifteen days into his contractual employment, Peronila was involved in a vehicular accident, resulting in an administrative investigation. Following this investigation, his employment contract was terminated, and he was denied renewal.
Legal Proceedings and NLRC Rulings
On January 18, 1989, Peronila filed a case for illegal dismissal, claiming constructive dismissal due to refusal of assignment after his contract ended. The Labor Arbiter dismissed his complaint, emphasizing the defined nature of his one-month contract. However, the NLRC overturned this decision, deeming Peronila's dismissal illegal for lack of just cause and ordered his reinstatement along with back wages.
Supreme Court Analysis
The Supreme Court reviewed the NLRC's ruling to determine the validity of Peronila's employment contract, which stated no employer-employee relationship. The Court concluded that Peronila's reemployment was more of an act of goodwill than a legal obligation, given his past infractions. It noted that the contract's parameters adhered to the stipulations under Article 280 of the Labor Code, affirming that the nature of employment can be affected by the intentions and agreements of both parties, and did not violate workers' rights to tenure.
Conclusions on Employment Status
Ultimately, the Court established that the employment contract signed by Peronila allowed for a fixed term that was not invalid under the law, provided there was no intention b
...continue readingCase Syllabus (G.R. No. 106654)
Case Overview
- This special civil action for certiorari seeks to nullify two resolutions from the National Labor Relations Commission (NLRC) dated July 2, 1992, and August 11, 1992.
- The resolutions held that Rodolfo Peronila was illegally dismissed from his employment with Pantranco North Express, Inc., resulting in imposed sanctions against the petitioners.
Background of the Case
- Rodolfo Peronila was employed as a driver by Pantranco North Express, Inc. in 1971, a corporation engaged in public transportation.
- In 1973, Peronila was subjected to an administrative investigation due to unauthorized absence of over two and a half months. He claimed this absence was due to attending his grandfather's funeral in Cotabato.
- The company found his explanation insufficient and dismissed him for violating company policies, following an order from Mediator-Factfinder Loreto V. Poblete which affirmed the dismissal.
Re-employment and Subsequent Events
- In 1988, fifteen years after his dismissal, Peronila requested to be reinstated. Initially denied, he was eventually rehired on a contractual basis for one month.
- The terms of this new employment included a daily wage of P64.00 and specified that there was no employer-employee relationship, thus denying him benefits like sick leave and vacation pay.
- Shortly after re-employment, Peronila was involved in a vehicular accident while driving a company bus, leading to his termination due to the mishap.
Case Proceedings
- After his terminatio