G.R. No. 115569 May 27, 1997
Guinnux Interiors, Inc. and/or Gabriel Olives, Ramon Carreon, Fred Nerit and Cirilo Corbella, petitioners, vs. The National Labor Relations Commission (Second Division) and Romeo C. Balais and Reynaldo B. Cagsawa, respondents.

FACTS

Petitioner Guinnux Interiors, Inc. (QII) is engaged in the furniture and interior design business. Private respondents Romeo Balais and Reynaldo Cagsawa were employed as laborers in 1990, performing tasks such as sanding, varnishing, and installing furniture. In September 1990, QII was awarded the “Skyland Plaza Project,” estimated for completion within 120 days, and the respondents were assigned to it. Balais was dismissed on December 31, 1991, and Cagsawa on March 19, 1992, with QII claiming the project was nearing completion and that they were merely project employees. The respondents filed a complaint for illegal dismissal and monetary claims.
The Labor Arbiter dismissed the complaint, ruling that the respondents were project employees whose employment legally ended with the project’s completion. On appeal, the National Labor Relations Commission (NLRC) reversed this decision, declaring the respondents to have attained regular employee status and that their dismissal was illegal. It ordered their reinstatement with full back wages. QII’s motion for reconsideration was denied, prompting this petition for certiorari.

ISSUE

The core issue is whether private respondents Balais and Cagsawa were project employees, whose employment was fixed for a specific undertaking, or regular employees, whose dismissal without just or authorized cause was illegal.

RULING

The Supreme Court dismissed the petition and affirmed the NLRC’s decision. The Court emphasized that factual findings of the NLRC are generally accorded respect and finality unless shown to be capricious or arbitrary, a burden QII failed to discharge. The legal logic centered on the application of Article 280 of the Labor Code, which defines project employees and regular employees.
The Court found QII’s claim that the respondents were project employees unsupported by substantial evidence. Critically, QII failed to present any employment contract specifying that the respondents were hired for the Skyland Plaza Project’s duration. There was no proof the respondents were informed their engagement was coterminous with that project. Furthermore, the record showed the respondents had worked on four other projects for QII without separate contracts, indicating continuous service beyond a single undertaking.
The Court also rejected QII’s alternative claim that the respondents were mere trainees, noting their simple tasks of sanding and varnishing did not require the lengthy training periods cited and were, in fact, “necessary or desirable in the usual business or trade” of a furniture company. Since the respondents performed these usual and necessary duties for almost two years across multiple projects, they had attained the status of regular employees under the law. Their dismissal, based solely on the project’s alleged completion without proving it was the sole purpose of their engagement, was therefore illegal.