Case Summary (A.C. No. 7136)
Factual Background
• Each respondent was repeatedly hired on one-month or seasonal agreements to perform essential milling-season tasks (hauling cane, operating cranes/loaders, performing maintenance and laboratory work).
• No continuous year-round engagement; work was confined to the milling season, but contracts were renewed each season.
• On August 23, 2002, respondents filed complaints for regularization, CBA benefits, and attorney’s fees before the Labor Arbiter (LA).
Procedural History
• Labor Arbiter (Oct 9, 2002): Dismissed complaints, classifying respondents as project/seasonal employees whose services ended with each project/season.
• NLRC (July 22, 2005 decision; Apr 28, 2006 resolution): Reversed LA; declared respondents “regular employees” and awarded CBA benefits.
• Court of Appeals (Nov 29, 2007 decision; Jan 22, 2009 resolution): Upheld NLRC finding of regular status but denied CBA benefits, distinguishing “regular seasonal” workers as a separate bargaining unit.
• Supreme Court: Petition for review on certiorari under Rule 45 filed March 18, 2009.
Issues Presented
1. Whether respondents are regular employees of URSUMCO.
2. Whether those respondents who did not appeal before the NLRC may receive affirmative relief.
3. Entitlement to benefits under the Collective Bargaining Agreement (CBA).
Applicable Law
• 1987 Philippine Constitution (decision rendered 2014).
• Labor Code, Article 280 – Defines regular employment (activities usually necessary or desirable to business), project employment (fixed for a specific undertaking), seasonal employment (for duration of the season), and casual employment (residual category; one-year continuous service confers regular status).
• Jurisprudence on fixed-term contracts (Brent School, Inc. v. Zamora).
Employment Classification Framework
• Regular employment is determined by the necessity or desirability of the work to the employer’s usual business.
• Project or seasonal employment must be tied to a defined project or season, with services terminating upon its completion.
• Repeated or continuous seasonal engagements over one year may indicate regular status, but CBA coverage depends on the nature and duration of tasks relative to year-round operations.
Analysis on Respondents’ Classification
• Respondents’ tasks were indispensable to milling operations during each season, not tied to a discrete project with a fixed end beyond the season’s closure.
• They were rehired annually for identical work, demonstrating URSUMCO’s continuing need.
• No proof that they were free to obtain off-season employment or were separated from service during off-season—they were effectively on leave until re-engagement.
Finding: Regular Seasonal Employees
Under Article 280, respondents qualify as regular seasonal employ
Case Syllabus (A.C. No. 7136)
Nature of the Case
- Petition for review on certiorari under Rule 45 of the Rules of Court
- Challenge to the November 29, 2007 decision and January 22, 2009 resolution of the Court of Appeals in CA-G.R. CEB-SP No. 02028
- The CA had affirmed with modification the NLRC’s reversal of the Labor Arbiter’s dismissal of complaints for regularization and CBA benefits
Parties Involved
- Petitioners:
• Universal Robina Sugar Milling Corporation (URSUMCO)
• Rene Cabati (Business Unit General Manager) - Respondents: Twenty-two employees of URSUMCO, including Ferdinand Acibo, Roberto Aguilar, Eddie Baldoza, Rene Abellar, Diomedes Alicos, Miguel Alicos, Rogelio Amahit, Larry Amasco, Felipe Balansag, Romeo Balansag, Manuel Bangot, Andy Banjao, Dionisio Bendijo Jr., Joventino Broce, Enrico Literal, Rodger Ramirez, Bienvenido Rodriguez, Diocito Palagtiw, Ernie Sablan, Richard Pancho, Rodrigo Estrabela, Danny Kadusale, and Allyrobyl Olpus
- Seven respondents appealed to the NLRC; all joined the CA and Supreme Court proceedings
Factual Antecedents
- URSUMCO is engaged in sugar-cane milling; Cabati serves as its Business Unit General Manager
- Respondents were hired between February 1988 and April 1996 in various capacities (drivers, crane operators, hookers, welders, mechanics, laboratory attendants, carpenters, masons, laborers)
- Each engagement was by one-month or seasonal contract, renewed repeatedly for the same tasks
- On August 23, 2002, respondents filed complaints before the Labor Arbiter for:
• Regularization
• Entitlement to benefits under the Collective Bargaining Agreement (CBA)
• Attorney’s fees
Procedural History
- October 9, 2002: Labor Arbiter dismissed the complaints as lacking merit, ruling respondents were seasonal/project employees
- July 22, 2005: NLRC reversed the Labor Arbiter; declared respondents regular employees and awarded CBA benefits
- April 28, 2006: NLRC denied petitioners’ motion for reconsideration
- November 29, 2007: Court of Appeals partially granted petition for certiorari, a