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UNIVERSAL ROBINA SUGAR MILLING CORPORATION v. FERDINAND ACIBO

FACTS:

This case involves a petition for review on certiorari challenging the decision and resolution of the Court of Appeals (CA) in CA-G.R. CEB-SP No. 02028. The CA decision affirmed with modification the decision and resolution of the National Labor Relations Commission (NLRC) in NLRC Case No. V-00006-03 which, in turn, reversed the decision of the Labor Arbiter (LA).

The petitioners, Universal Robina Sugar Milling Corporation (URSUMCO) and Rene Cabati, are the respondents in this case. URSUMCO is a domestic corporation engaged in the sugar cane milling business, while Cabati is URSUMCO's Business Unit General Manager.

The respondents, Ferdinand Acibo, et al., are employees of URSUMCO and were hired on various dates between February 1988 and April 1996. They were hired for different capacities such as drivers, crane operators, bucket hookers, welders, mechanics, laboratory attendants and aides, steel workers, laborers, carpenters, and masons. The respondents signed contracts of employment for a period of one month or for a given season and were repeatedly hired by URSUMCO to perform the same duties.

On August 23, 2002, the respondents filed complaints before the LA for regularization, entitlement to benefits under the existing Collective Bargaining Agreement (CBA), and attorney's fees. The LA dismissed the complaint for lack of merit, ruling that the respondents were seasonal or project workers and not regular employees of URSUMCO. The LA held that the complainants were required to perform tasks in phases of URSUMCO's projects that were not directly related to its main operations. The LA also stated that the complainants' employments were coterminous with the phase of the work or special project to which they were assigned.

Seven of the twenty-two complainants appealed the decision of the LA before the NLRC. In its decision, the NLRC reversed the LA's ruling, declaring the complainants as regular URSUMCO employees and granting their monetary claims under the CBA. The NLRC held that the complainants performed activities necessary and desirable in URSUMCO's trade or business and had been repeatedly hired for the same undertaking every season.

The petitioners moved to reconsider the NLRC ruling, but it was denied. They then elevated the case to the CA, which affirmed the NLRC's ruling but deleted the grant of monetary benefits under the CBA. The CA held that the complainants were regular URSUMCO employees based on the nature of their work, but they were not entitled to CBA benefits because they did not belong to the bargaining unit of regular employees.

The petitioners filed a petition for review with the Supreme Court after the CA denied their motion for partial reconsideration. The Court was asked to resolve whether the respondents are regular employees of URSUMCO and whether affirmative relief can be given to the fifteen complainants who did not appeal the LA's decision.

ISSUES:

  1. Whether the respondents are regular employees or contractual/project/seasonal workers.

  2. Whether the legal parameters for regular employment apply to the respondents' case.

  3. Whether the employment of the respondents should be classified as regular seasonal employment or fixed-term employment.

  4. Whether the respondents are entitled to the benefits granted to regular employees under the Collective Bargaining Agreement (CBA).

  5. Whether the Court of Appeals properly analyzed the NLRC decision and affirmed the respondents' status as regular seasonal employees.

  6. Whether the NLRC's declaration of the respondents as regular employees constitutes grave abuse of discretion.

RULING:

  1. The Court finds the respondents to be regular seasonal employees of URSUMCO. The nature of their engagement, being continuously working for URSUMCO for more than one year and performing tasks necessary and desirable to the company's business, qualifies them as regular employees. The Court disagrees with the petitioners' argument that the legal standards for regular employment only apply to regular employees under Article 280 of the Labor Code. The length of time of engagement and the necessity or desirability of the employee's work also apply to casual employees who are deemed regular by their length of service.

  2. The employment of the respondents should be classified as regular seasonal employment. The respondents were tasked to perform duties regularly and habitually needed in the employer's operations during the milling season. They were repeatedly hired to perform the same tasks year after year. The nature of their employment thus falls under regular seasonal employment, where they are considered on leave during the off-season and are not separated from the service.

  3. The respondents are not entitled to the benefits granted to regular employees under the CBA. They should not be confused with the regular employees of the sugar mill who perform tasks for the entire year regardless of the season. The National Labor Relations Commission (NLRC) gravely erred in declaring the respondents as regular employees entitled to such benefits.

  4. The Court found that the Court of Appeals misappreciated the NLRC ruling and missed the implications of the respondents' regularization. The NLRC did not declare the respondents as regular seasonal employees, but as regular employees entitled to the benefits under the CBA for regular employees. The Court ruled that the NLRC's decision constituted grave abuse of discretion as it ignored the distinctions between regular and regular seasonal employees and disturbed the system of regular seasonal employment already in place in the sugar industry. The Court set aside the Court of Appeals' decision and dismissed the complaint for lack of merit.

PRINCIPLES:

  • Regular employment is defined as an arrangement where the employee performs activities necessary or desirable to the usual business or trade of the employer.

  • Casual employment may be considered regular when the casual employee's engagement has lasted for at least one year, regardless of the continuity of engagement.

  • Project employment involves an arrangement where the employee is hired for a specific project or undertaking with a clear determination of the completion or termination of the project at the time of engagement.

  • Seasonal employment involves work or service that is seasonal in nature or lasting for the duration of the season. Continuously and repeatedly hiring seasonal workers for the same tasks or activities for several seasons or even after the cessation of the season may indicate regular employment.

  • Casual employment refers to any other employment arrangement that does not fall under regular or project/seasonal categories.

  • Only questions of law are allowed in a petition for review on certiorari. The Court's power of review in a Rule 45 petition is limited to resolving matters pertaining to perceived legal errors committed by the CA.

  • In reviewing the legal correctness of the CA's Rule 65 decision in a labor case, the Court examines it in the context of determining the presence or absence of grave abuse of discretion in the NLRC decision before it.

  • Regular seasonal employees cannot automatically be governed by the CBA between the employer and the authorized bargaining representative of regular and permanent employees due to differences in the nature of their duties and the duration of their work.

  • Distinctions between regular and regular seasonal employees must be acknowledged and maintained, especially in industries with seasonal operations.