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FAR EAST AGRICULTURAL SUPPLY v. JIMMY LEBATIQUE

FACTS:

Far East Agricultural Supply, Inc. hired Jimmy Lebatique as a truck driver on March 4, 1996. On January 24, 2000, Lebatique complained about nonpayment of overtime work and was suspended by Manuel Uy, the brother of Far East's General Manager. The following day, Lebatique reported for work but was not allowed to enter the company premises. On January 26, 2000, Lebatique sought the assistance of the Department of Labor and Employment (DOLE) regarding the nonpayment of his overtime pay. He received a telegram from the petitioners requiring him to report for work, and when he did, Alexander Uy questioned him about his claim for overtime pay. Lebatique explained that he had never been paid for overtime work, and after speaking with Manuel, Alexander terminated Lebatique and told him to find another job. Consequently, Lebatique filed a complaint for illegal dismissal and nonpayment of overtime pay on March 20, 2000.

The Labor Arbiter ruled in favor of Lebatique, finding his dismissal to be illegal, and ordered his reinstatement as well as payment for backwages, 13th month pay, service incentive leave pay, and overtime pay. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision and dismissed the complaint. However, the Court of Appeals (CA) later reversed the NLRC's decision and reinstated the Labor Arbiter's ruling. As a result, the petitioners filed a petition for review on certiorari to challenge the CA's decision.

ISSUES:

  1. Whether Lebatique was illegally dismissed.

  2. Whether Lebatique was a field personnel, not entitled to overtime pay.

RULING:

  1. Lebatique was illegally dismissed.

  2. Lebatique was not a field personnel and is entitled to overtime pay.

PRINCIPLES:

  • An employee is considered illegally dismissed if there is a termination of employment without just cause and due process.

  • Field personnel are those whose performance is unsupervised by the employer and are not required to report to an office or workstation on a regular basis.

  • Field personnel are entitled to overtime pay unless exempted under the Labor Code or any applicable collective bargaining agreement.