FACTS:

The case involves the Petition for Review filed by Rowell Industrial Corp. (RIC), a corporation engaged in manufacturing tin cans, seeking to set aside the Decision and Resolution of the Court of Appeals affirming the Resolutions of the NLRC. The NLRC found the respondent, Joel Taripe, to be a regular employee who was illegally dismissed by RIC.

Joel Taripe was employed by RIC as a rectangular power press machine operator. He filed a complaint against RIC for regularization, payment of holiday pay, and indemnity for his severed finger. Taripe alleged that he was a regular employee and was terminated without cause, violating company rules.

On the other hand, RIC claimed that Taripe was a contractual employee whose contract expired, and all benefits entitled to him were already provided. The Labor Arbiter dismissed Taripe's complaint, but the NLRC reversed the decision and ruled that Taripe should be considered a regular employee.

The Court of Appeals affirmed the NLRC's decision with modifications. The appellate court exonerated Edwin Tang from any liability and computed Taripe's backwages based on his last salary. RIC argues that the Court of Appeals misinterpreted Article 280 of the Labor Code and disregarded the voluntary contract entered into by the parties.

ISSUES:

1. Whether or not respondent Taripe is a regular employee.

2. Whether or not the employment contract stating a fixed period can prevail over the determination of regular employment status.

3. Whether or not the employment contract between petitioner RIC and respondent Taripe is a valid fixed-term employment contract.

4. Whether or not respondent Taripe is a regular employee of petitioner RIC.

5. Whether the summary dismissal of the respondent, not being based on any of the just or authorized causes enumerated under Articles 282, 283, and 284 of the Labor Code, as amended, is illegal.

RULING:

1. The Court of Appeals ruled that respondent Taripe is a regular employee of the petitioner and that his dismissal was illegal. The court applied Article 280 of the Labor Code, which provides for two kinds of regular employees: those engaged in activities usually necessary or desirable in the usual business or trade of the employer and those who have rendered at least one year of service. Respondent Taripe belonged to the first category.

2. The Court of Appeals held that the purported contract of employment stating a fixed period cannot prevail over the fact that respondent Taripe was hired to perform a function necessary or desirable in the petitioner's business. The length of service is only relevant when the activity performed is not necessary or desirable to the employer's business.

3. The employment contract between petitioner RIC and respondent Taripe is not a valid fixed-term employment contract. It fails to meet the necessary guidelines for a valid fixed-term employment contract, namely, that the fixed period of employment was knowingly and voluntarily agreed upon by the parties without any force or duress, and that the employer and employee dealt with each other on more or less equal terms. The contract did not mention that respondent Taripe's services were seasonal in nature or that his employment was only for the duration of the Christmas season. Furthermore, it was shown that respondent Taripe was compelled to sign the contract as a condition for his hiring. Thus, the contract was a mere subterfuge to deny him regular employment status.

4. Respondent Taripe is a regular employee of petitioner RIC. His position as a rectangular power press machine operator, which was necessary and desirable in the usual business or trade of petitioner RIC, made him a regular employee by the nature of the work he performed in the company. He does not fall under the exceptions mentioned in Article 280 of the Labor Code, as amended, as it was not proven that he was employed only for a specific project or undertaking or that his employment was merely seasonal. Therefore, he enjoys security of tenure and can only be dismissed for just cause and with due process.

5. The court held that the summary dismissal of the respondent, not being based on any of the just or authorized causes enumerated under Articles 282, 283, and 284 of the Labor Code, as amended, is indeed illegal. The decision and resolution of the Court of Appeals were affirmed, which found the respondent as a regular employee who had been illegally dismissed from employment by the petitioner.

PRINCIPLES:

• Article 280 of the Labor Code classifies employees into regular employees, project employees, and casual employees.

• Regular employees can be classified as regular employees by nature of work and regular employees by years of service.

• An employment contract stating a fixed period does not necessarily contradict the nature of the employee's duties, as long as such activities are necessary or desirable to the employer's business.

• Article 280 of the Labor Code aims to prevent employers from circumventing laws protecting workers from capricious dismissal, but it should not be interpreted to deprive employers of their rights to choose their own workers based on valid grounds.

• Fixed-term employment contracts must meet certain guidelines in order to be deemed valid and not circumvent security of tenure.

• A contract of adhesion, where one party's participation is reduced to "take it or leave it," is generally not considered to be entered into on equal terms.

• The primary standard of determining regular employment is the reasonable connection between the particular activity performed by the employee and the casual business or trade of the employer.

• Regular employees enjoy security of tenure and can only be dismissed for just cause and with due process, notice, and hearing. The burden of proving the legality of the dismissal rests on the employer.

• Factual findings of the National Labor Relations Commission (NLRC), affirmed by the Court of Appeals, are generally accorded respect and finality, especially when such findings are within its jurisdiction. Such factual findings are binding on the Supreme Court.