Philippine Fruit & Vegetable Industries, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Philippine Fruit and Vegetable Workers Union-Tupas Local Chapter, on behalf of 127 members, filed a complaint for unfair labor practice and/or illegal dismissal against petitioner Philippine Fruit & Vegetable Industries, Inc. (PFVII) and its President and General Manager, Pedro Castillo. The union alleged that its members, who worked for San Carlos Fruits Corporation before its incorporation into PFVII, were dismissed due to their union activities and without just cause. The number of complainants later increased to 160 and then to 194. Procedural History: Labor Arbiter Ricardo Olairez initially ruled in favor of the employees, finding illegal dismissal. This decision was set aside by the NLRC on appeal and remanded for further proceedings. Labor Arbiter Quintin C. Mendoza subsequently rendered a decision finding petitioners liable for illegal dismissal and ordering them to pay 190 complainants backwages, 13th month pay, and separation pay if reinstatement was not feasible, plus attorney's fees. The NLRC affirmed this decision with modification regarding attorney's fees and denied petitioners' motion for reconsideration. The Petition: Petitioners assailed the NLRC's decision and resolution, arguing that the NLRC's findings were unsubstantiated, that the employees were seasonal workers whose employment ceased due to the off-season, that PFVII was separate from San Carlos Fruits Corporation, that employees refused medical examinations, and that only 78 out of 194 complainants testified to substantiate their claims.
Issue(s)
Whether the NLRC's findings of fact are supported by evidence, applicable laws, and jurisprudence. Whether the private respondents are regular seasonal employees entitled to security of tenure, having been illegally dismissed instead of their employment ceasing due to the off-season. Whether the Labor Arbiter and the NLRC committed manifest error in ordering the petitioner to pay 194 individuals backwages, 13th month pay, and separation pay benefits, specifically regarding the evidence required to support individual claims.
Ruling
The Supreme Court affirmed the questioned decision of the NLRC insofar as the 80 union members who were able to prove their respective claims are concerned, but reversed it with respect to the other 114 union members who did not adduce evidence in support of their claims.
Ratio Decidendi
On the issue of whether the NLRC's findings of fact are supported by evidence, applicable laws, and jurisprudence: The Court held that findings of fact of the National Labor Relations Commission (NLRC), affirming those of the Labor Arbiter, are entitled to great weight and will not be disturbed if supported by substantial evidence. The Labor Arbiter's decision noted that the employment of most complainants started in 1983 and that the company operated throughout the year, processing various fruits and vegetables, and also maintained office administrative functions and machine upkeep. The NLRC further found that the services of the complainants were more than six months a year, considering the company's diverse processing activities and operational functions. Therefore, the findings of both the Labor Arbiter and the NLRC were deemed supported by substantial evidence, warranting no reversal. On the issue of whether the private respondents are regular seasonal employees entitled to security of tenure, having been illegally dismissed instead of their employment ceasing due to the off-season: The Court reiterated that under Article 280 of the Labor Code, an employment is deemed regular where the employee has been engaged to perform activities usually necessary or desirable in the employer's usual business or trade, or has rendered at least one year of service. The work of the complainants as seeders, operators, sorters, slicers, janitors, drivers, truck helpers, mechanics, and office personnel was considered necessary and desirable in the usual business of a food processing company. The Court also noted that their employment was not fixed for a specific project and that while some processing phases might be seasonal, other aspects like manufacturing and marketing were not, and large-scale food processing companies operate year-round. Thus, the complainants were classified as regular seasonal employees entitled to security of tenure. On the issue of whether the Labor Arbiter and the NLRC committed manifest error in ordering the petitioner to pay 194 individuals backwages, 13th month pay, and separation pay benefits, specifically regarding the evidence required to support individual claims: The Court found that only 80 out of the 194 union members presented evidence to support their claims, such as affidavits, testimonies, pay slips, passbooks, and identification cards. It is a basic rule that each party must prove their affirmative allegations. The Court held that the Labor Arbiter erred in appreciating the evidence presented by the complaining union members in favor of the other 114, as the evidence is personal to each claimant. Therefore, only those members who were able to prove their claims are entitled to awards of backwages, 13th month pay, and separation pay.
Main Doctrine
The Supreme Court affirmed the National Labor Relations Commission's finding that the complainants were regular employees, not seasonal workers, as their tasks were necessary and desirable to the usual business of the food processing company, and thus were entitled to security of tenure and benefits. However, the Court reversed the award for 114 union members who failed to present evidence to substantiate their claims.