Philippine Federation of Credit Cooperatives, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Victoria Abril was employed by petitioner Philippine Federation of Credit Cooperatives, Inc. (PFCCI) in September 1982. She held various positions, including Junior Auditor/Field Examiner, office secretary, and cashier-designate. After taking a leave of absence for childbirth, she returned in November 1989 to find her former position permanently filled. She accepted a new position as Regional Field Officer under a contract stipulating a six-month probationary period. After this period elapsed, PFCCI presented another contract for a one-year term (January 2, 1991, to December 31, 1991). Her employment was terminated after this one-year period. Procedural History: Respondent filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint for lack of merit but ordered PFCCI to reimburse P2,500.00 deducted from her salary. On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, directing PFCCI to reinstate the complainant with full backwages. The Petition: PFCCI filed a petition for certiorari, arguing that respondent's employment was either casual or contractual, fixed for a specific project, and thus not regular employment. They contended that the NLRC committed grave abuse of discretion.
Issue(s)
Whether the respondent Victoria Abril became a regular employee entitled to security of tenure. Whether the employment contract was ambiguous and how such ambiguity should be resolved. Whether the dismissal of the respondent was legal.
Ruling
The petition is dismissed, and the decision of the National Labor Relations Commission is affirmed. The dismissal of the respondent was illegal.
Ratio Decidendi
On Whether Victoria Abril Became a Regular Employee: The Court affirmed the NLRC's finding that respondent Victoria Abril became a regular employee. It reiterated the elementary rule that a probationary employee engaged to work beyond the probationary period is considered a regular employee. The Court noted that respondent completed her initial six-month probationary period as Regional Field Officer and was allowed to work thereafter. Regardless of the designation given to her employment status, having completed the probationary period and continued working, she attained regular status, entitling her to security of tenure. This status means she could only be dismissed for just or authorized causes under Articles 282, 283, and 284 of the Labor Code, as amended. The dismissal premised on the alleged expiration of the contract was therefore illegal. On the Ambiguity of the Employment Contract: The Court found the employment contract to be ambiguous. While initial statements suggested a fixed-period or contractual employment, subsequent provisions indicated a probationary status. The Court applied the principle that where a contract of employment, being a contract of adhesion, is ambiguous, any ambiguity should be construed strictly against the party who prepared it, which was PFCCI. Furthermore, Article 1702 of the Civil Code mandates that in case of doubt, all labor contracts shall be construed in favor of the laborer. The Court rejected PFCCI's interpretation, which would result in a violation of the respondent's right to security of tenure. On the Legality of the Dismissal: The Court concluded that the dismissal of respondent Victoria Abril was illegal. Since she had attained regular employee status by completing her probationary period and continuing to work, her employment could not be terminated simply due to the alleged expiration of a contract. Such termination, without just or authorized cause, violates her constitutional and statutory right to security of tenure. Therefore, the NLRC's directive for reinstatement with full backwages was affirmed.
Main Doctrine
A probationary employee who is allowed to work beyond the probationary period is considered a regular employee entitled to security of tenure. Ambiguous employment contracts are construed in favor of the laborer.