University of Santo Tomas v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Librado Canicosa was employed by the University of Santo Tomas (UST) as an instructor in its Faculty of Medicine and Surgery and, informally, as its Medical Officer for the employees of the University and its hospital, starting in July 1950. Over the years, his role as Medical Officer evolved, with his duties and compensation being formally defined in 1975 as Personnel Health Officer with a fixed term ending October 31, 1975. Canicosa had previously expressed dissatisfaction with his status and had openly denounced UST's management for alleged labor law violations and opposed the citizenship application of a hospital administrator. Upon returning from an approved leave of absence in September 1975, he discovered another individual had been appointed to his position, and he was informed his term had expired and he was not reappointed. 2. Procedural History: Librado Canicosa filed a complaint for illegal dismissal and underpayment against UST and its officials. Labor Arbiter Jose T. Collado, Jr. ruled in favor of Canicosa, ordering his reinstatement with full backwages. The University of Santo Tomas appealed this decision to the National Labor Relations Commission (NLRC). The NLRC affirmed the Labor Arbiter's decision, dismissing the appeal for lack of merit. This affirmation by the NLRC led to the current petition before the Supreme Court. 3. The Petition: The petitioners, UST and its officials, seek to annul the decisions of the Labor Arbiter and the NLRC. They argue that Canicosa implicitly accepted the terms of the newly organized Personnel Health Officer position, including its fixed term, by not protesting all features except the salary, thereby abandoning his old office. They further contend that the NLRC erred in applying the amended version of Article 270 of the Labor Code to Canicosa's employment, which had a fixed term ending prior to the amendment's effective date. Petitioners assert that employment with a fixed period was valid under the Labor Code provisions in effect at the time. They also dispute the NLRC's finding that the fixed term was intended to ease Canicosa out of service due to his prior denunciations of management, claiming this conclusion lacks evidentiary support.
Issue(s)
Whether the respondent Canicosa's employment as Personnel Health Officer with a fixed term was regular employment protected by security of tenure. Whether the NLRC committed grave abuse of discretion in applying the amended Article 270 of the Labor Code to the case.
Ruling
The petition is dismissed. The National Labor Relations Commission did not commit grave abuse of discretion. The employment of respondent Librado Canicosa is deemed regular and entitled to security of tenure.
Ratio Decidendi
On Issue 1: The Court held that respondent Canicosa's employment was regular and entitled to security of tenure. It found that the positions of Medical Officer and Personnel Health Officer were essentially the same, involving the same duties of serving the medical needs of the employees. The change in designation and the slight salary increase did not alter the fundamental nature of the employment. The Court reiterated that an employment is deemed regular if the employee performs activities usually necessary or desirable in the employer's usual business or trade. Since Canicosa had been performing these duties for 25 years, his employment had attained a regular status. The fixing of a term for his position was considered oppressive and arbitrary, a circumvention of his right to security of tenure, and thus ineffective. The Court emphasized that even if Canicosa tacitly agreed to the fixed term, it did not affect his regular status, as the law protects security of tenure. On Issue 2: The Court found no merit in the contention that the NLRC committed grave abuse of discretion by applying the amended Article 270 of the Labor Code. The Court clarified that whether the original or amended provisions of Article 270 were applied, the criterion for determining regular employment remained the same: whether the employee was engaged to perform activities usually necessary or desirable in the employer's usual business or trade. Under both versions of the law, Canicosa's employment was considered regular due to the nature of his duties. Therefore, his termination without just cause or authorization under the Labor Code was illegal. The Court concluded that petitioners' "indulgence over a web of 'legal niceties' is merely an exercise in futility" as the outcome would be the same regardless of which version of the law was applied.
Main Doctrine
The Supreme Court affirmed the National Labor Relations Commission's decision, holding that respondent Librado Canicosa's employment as Medical Officer and later Personnel Health Officer was regular and entitled to security of tenure. The Court emphasized that even if an employment contract specifies a fixed term, it is deemed regular if the employee performs activities usually necessary or desirable in the employer's usual business or trade. This principle applies regardless of whether the original or amended provisions of the Labor Code concerning employment without a fixed period are considered, as the core criterion remains the nature of the work performed.