Universal Robina Sugar Milling v. Acibo
REITERATIONFacts
The Antecedents: Petitioners Universal Robina Sugar Milling Corporation (URSUMCO) and its Business Unit General Manager, Rene Cabati, were sued by their employees (respondents) for regularization and entitlement to benefits under the Collective Bargaining Agreement (CBA). The respondents were hired on various dates between February 1988 and April 1996 as drivers, crane operators, welders, mechanics, and laborers, among others. They signed one-month or seasonal employment contracts, and URSUMCO repeatedly rehired them for the same duties. Procedural History: The Labor Arbiter (LA) dismissed the complaint, holding the respondents were seasonal or project workers, not regular employees, and thus not entitled to CBA benefits. Seven respondents appealed to the National Labor Relations Commission (NLRC). The NLRC reversed the LA, declaring the respondents as regular employees and granting their monetary claims under the CBA. The NLRC denied URSUMCO's motion for reconsideration. The Court of Appeals (CA) affirmed the NLRC's ruling that the respondents were regular employees but deleted the grant of CBA benefits, reasoning that regular seasonal workers constitute a separate bargaining unit distinct from regular employees covered by the CBA. The Petition: URSUMCO and Cabati filed a petition for review on certiorari, challenging the CA's decision and resolution. The issues presented were whether the respondents are regular employees of URSUMCO and whether affirmative relief could be given to complainants who did not appeal the LA's decision.
Issue(s)
Whether the respondents are regular employees of URSUMCO. Whether affirmative relief can be given to the fifteen (15) of the complainants who did not appeal the LA’s decision.
Ruling
The petition is PARTIALLY GRANTED. The November 29, 2007 decision and the January 22, 2009 resolution of the Court of Appeals are SET ASIDE, except for the denial of the respondents' claim for CBA benefits. The complaint is DISMISSED for lack of merit.
Ratio Decidendi
On the issue of the status of the respondents’ employment: The Court disagreed with the petitioners' position that the respondents were contractual or project/seasonal workers. It found the respondents to be regular seasonal employees of URSUMCO. The Court reiterated the definition of regular employment under Article 280 of the Labor Code, emphasizing the necessity or desirability of the employee's activity to the employer's business. It clarified that project employment requires a specific project with a determined completion date, while seasonal employment involves work seasonal in nature. The Court noted that even seasonal workers can attain regular status if repeatedly hired for the same tasks over several seasons. The Court found that the respondents performed duties regularly and habitually needed in URSUMCO's operations during the milling season, such as hauling sugarcane and ensuring the mill's continuous operation, which were necessary and desirable to URSUMCO's business. The respondents were regularly and repeatedly hired for the same tasks year after year, establishing a system of regular seasonal employment. The Court distinguished this from project employees whose services are coterminous with the project. The Court also found no evidence that the respondents sought or obtained employment elsewhere during the off-season, contrary to the petitioners' assertion. The Court found the case of Mercado, Sr. v. NLRC inapplicable due to different factual considerations. On the issue of affirmative relief to complainants who did not appeal: This issue became academic with the dismissal of the complaint.
Main Doctrine
Employees performing activities that are necessary and desirable in the usual business or trade of the employer, and who are repeatedly hired for the same tasks year after year, are considered regular seasonal employees, even if their employment is for a fixed period or season, unless the employer proves they had the opportunity to work elsewhere during the off-season. Regular seasonal employees are distinct from regular employees covered by a Collective Bargaining Agreement (CBA) if the latter perform tasks year-round irrespective of the season.