FACTS:

The Leyte Geothermal Power Progressive Employees Union - ALU-TUCP (petitioner Union) filed a petition for certiorari to challenge the decision of the National Labor Relations Commission (NLRC) in NLRC Certified Case No. V-02-99. The petitioner Union, a legitimate labor organization, demanded recognition as the collective bargaining agent for the employees hired on a contractual basis by respondent Philippine National Oil Corporation-Energy Development Corporation (PNOC-EDC). However, PNOC-EDC refused to recognize the petitioner Union and proceeded to terminate the employment of the employees. A notice of strike was filed by the petitioner Union, but the Secretary of Labor intervened and ordered a cease of the strike. The petitioner Union remained steadfast in its position, resulting in a complaint for strike illegality, declaration of loss of employment, and damages filed by PNOC-EDC. The NLRC ruled in favor of PNOC-EDC, declaring the termination of employment valid and the strike illegal. The Court of Appeals affirmed the NLRC decision, prompting the petitioner Union to appeal through a petition for certiorari.

The petitioner Union raised several questions of law in its petition challenging the Court of Appeals decision. It questioned the validity of the "project contracts" used by respondent PNOC-EDC to deny the employees their right to security of tenure. The petitioner Union also argued that the employees cannot be considered project employees if there were no intervals in their employment contracts, and questioned whether the completion of the project justified the dismissal of the employees. The respondent argued that the officers and members of the petitioner Union were project employees because their activities were necessary and desirable for its usual business.

The Court, in addressing these issues, examined the distinction between regular and project employment as provided in the Labor Code. It clarified that regular employees are engaged in activities usually necessary or desirable for the employer's trade or business, while project employees are hired for specific projects with predetermined completion or termination. The Court recognized the validity of project employment contracts, stating that the employees should be aware that their employment is tied to the completion of the project and continuous employment cannot be expected beyond that. It emphasized that project employment contracts are not inherently prejudicial to employees and that their interests are still protected by the law. The records of the case showed that the officers and members of the petitioner Union were engaged as project employees.

During the trial, it was established that the individual members of the petitioner Union freely and voluntarily signed and accepted the employment contracts. The petitioner Union failed to present any evidence to prove that there was improper pressure or undue influence when the contracts were entered into. The contracts of employment were read, understood, and voluntarily accepted by the members of the petitioner Union, as confirmed by the Union's President.

ISSUES:

1. Whether the officers and members of petitioner Union are project employees of respondent.

2. Whether the officers and members of petitioner Union engaged in an illegal strike.

RULING:

1. The Supreme Court ruled that the officers and members of petitioner Union were indeed project employees of respondent. The Court held that these employees were hired for a specific project or phase of work, with the duration determinable at the time of their engagement, making their employment terminable upon the project's completion.

2. The Supreme Court upheld the findings that petitioner Union engaged in an illegal strike. The Court found that the Union failed to comply with the mandatory requirements under the law for holding a strike, including the failure to conduct a strike vote, observe the cooling-off period, and comply with the seven-day strike ban post-strike vote submission.

PRINCIPLES:

1. Project Employment: An employment relationship based on a specific project or undertaking, with a fixed period determined at the time of the engagement, which is terminable upon project completion.

2. Article 280 of the Labor Code: Establishes the distinction between regular and project employees, stating that project employees are those hired for a specific project or undertaking, with its scope and duration determinable at the outset.

3. Validity of Project Employment Contracts: Even in the presence of continuous work or no interval in employment contracts, project employment contracts indicating a specific project or phase remain valid, provided they were entered into freely and voluntarily without undue pressure.

4. Illegal Strike: To be considered legal, a strike must comply with requirements such as filing a notice of strike, observing a cooling-off period, and conducting a strike vote. Any failure in these requisites renders the strike illegal.

5. Factual Findings of Administrative Bodies: Findings of fact by quasi-judicial bodies like the NLRC are generally accorded respect and finality when supported by substantial evidence and will not be disturbed by higher courts absent any inconsistency with other factual findings.

6. Union Busting: Claims of union busting must be substantiated by evidence showing the employer's deliberate aim to destabilize or dissolve the union.