Hacienda Fatima v. National Federation of Sugarcane Workers-Food and General Trade
REITERATIONFacts
The Antecedents: The National Labor Relations Commission (NLRC) found that the employers (petitioners) did not look favorably upon the workers organizing into a union. After the union was certified as the collective bargaining representative, the employers refused to negotiate a collective bargaining agreement (CBA), citing an appeal on the election results. The workers were not given work for over a month, leading to a strike. A Memorandum of Agreement (MOA) was signed, stipulating, among other things, priority for women workers, provision of wagons, priority for existing workforce, and non-employment of scabs. However, the employers allegedly reneged on their commitment, claiming the workers failed to load the wagons, and used private armed guards to prevent union organizers from entering the premises. Starting September 1991, the employers stopped giving work assignments to the complainants, prompting another strike. A second MOA was signed, agreeing to settle the dispute amicably and to form a committee to determine the status of 36 union members based on the 1990 payroll and other employment references. A Minutes of Conciliation Meeting indicated that certain individuals were deemed not employees, while others were to be reinstated upon availability of work. When the employers again reneged on their commitment, the complainants filed a complaint. Procedural History: The Labor Arbiter initially found that the complainants refused to work or were choosy. However, the NLRC set aside the Labor Arbiter's decision, declaring that the complainants had been illegally dismissed. The NLRC ordered reinstatement (except for four individuals) with full backwages and awarded moral and exemplary damages to the union for unfair labor practice. The Court of Appeals (CA) affirmed the NLRC decision, holding that the respondents were regular employees despite their work being seasonal, as they were considered on leave during the off-season and enjoyed security of tenure. The CA also concurred with the NLRC's finding of unfair labor practice. The Petition: The employers filed a Petition for Review with the Supreme Court, assailing the CA's decision for allegedly erring in holding that seasonal workers were regular employees, in rejecting the ruling in Mercado v. NLRC, and in upholding the NLRC's conclusion of illegal dismissal and unfair labor practice.
Issue(s)
A. Whether or not the Court of Appeals erred in holding that respondents, admittedly seasonal workers, were regular employees, contrary to the clear provisions of Article 280 of the Labor Code. B. Whether or not the Court of Appeals erred in rejecting the ruling in Mercado, supra, and relying instead on rulings which are not directly applicable to the case at bench. C. Whether or not the Court of Appeals committed grave abuse of discretion in upholding the NLRC's conclusion that private respondents were illegally dismissed, that petitioners were guilty of unfair labor practice, and that the union be awarded moral and exemplary damages.
Ruling
The Petition is denied, and the assailed Decision of the Court of Appeals is affirmed. Costs against petitioners.
Ratio Decidendi
On Issue A (Regular vs. Seasonal Employment): The Court affirmed the CA's ruling that the respondents were regular employees. Article 280 of the Labor Code requires not only that the work be seasonal in nature but also that the employment be for the duration of that season to exclude an employee from the definition of regular employment. Petitioners did not deny that the workers, with few exceptions, had worked for them for several years, indicating employment beyond a single season. The Court reiterated the principle that seasonal workers who are called to work from time to time and are temporarily laid off during the off-season are not separated from service but are considered on leave until re-employed, thus maintaining their status as regular employees. The repeated and continuing need for their performance is sufficient evidence of the necessity of their activity to the business, making their employment regular with respect to such activity. On Issue B (Applicability of Mercado v. NLRC): The Court found no error in the CA's ruling that Mercado v. NLRC was not applicable. In Mercado, the workers performed phases of agricultural work for a definite period and were available to any farm owner, not being hired regularly for the same tasks. In contrast, the herein respondents performed the same tasks for petitioners every season for several years, establishing them as regular employees for their respective tasks. The Court emphasized that the test for regular employment is the reasonable connection between the activity performed by the employee and the usual trade or business of the employer, and if the employee has performed the job for at least a year, even intermittently, the law deems the activity necessary and the employment regular. On Issue C (Illegal Dismissal and Unfair Labor Practice): The Court upheld the CA's affirmation of the NLRC's findings of illegal dismissal and unfair labor practice. The Court found that the employers' actions, such as sudden changes in work assignments and deprivation of jobs for union members, occurred immediately after the workers organized and demanded collective bargaining, indicating bad faith and interference with the right to self-organization. Such actions constituted unjustified dismissal and violated the Labor Code. The Court reiterated that the burden is on the employer to prove a clear, valid, and legal cause for termination, which petitioners failed to do. The NLRC's factual findings on unfair labor practice, supported by substantial evidence, were accorded great weight and finality.
Main Doctrine
Seasonal workers who have repeatedly worked for the employer for several years, even if only for the duration of a particular season, are considered regular employees if they are called to work from time to time and are temporarily laid off during the off-season, as they are merely considered on leave until re-employed. Refusal to give work assignments to such regular employees, especially after organizing a union, constitutes illegal dismissal and potentially unfair labor practice.