GR 149440; (January, 2003) (Digest)
G.R. No. 149440 January 28, 2003
HACIENDA FATIMA and/or PATRICIO VILLEGAS, ALFONSO VILLEGAS and CRISTINE SEGURA, petitioners, vs. NATIONAL FEDERATION OF SUGARCANE WORKERS-FOOD AND GENERAL TRADE, respondents.
FACTS
The respondents, sugarcane workers, were members of a union certified as the collective bargaining representative. After certification, petitioners refused to bargain. The workers staged a strike, leading to a Memorandum of Agreement (MOA) for CBA negotiations and work priority for union members. Petitioners later alleged the workers failed to load wagons and reneged on the agreement. Starting September 1991, petitioners stopped giving work assignments to the complainants, prompting another strike in January 1992. A second MOA was signed to determine the status of 36 union members using the 1990 payroll and other references. A committee identified four individuals as not employees and listed twelve for immediate reinstatement. Petitioners again reneged, leading to the filing of the complaint for illegal dismissal and unfair labor practice. The Labor Arbiter dismissed the complaint, but the NLRC reversed, declaring illegal dismissal and unfair labor practice, ordering reinstatement with backwages and awarding moral and exemplary damages. The Court of Appeals affirmed the NLRC decision.
ISSUE
1. Whether the Court of Appeals erred in holding that the respondents, who performed seasonal work, were regular employees under Article 280 of the Labor Code.
2. Whether the Court of Appeals committed grave abuse of discretion in upholding the NLRC’s findings of illegal dismissal, unfair labor practice, and the award of damages.
RULING
The Supreme Court DENIED the petition and AFFIRMED the assailed Decision.
1. On the issue of regular employment: The Court ruled that while the work performed was seasonal in nature, for exclusion from regular employment under Article 280, it is not enough that the work is seasonal; the employment must also be for the duration of one season only. Petitioners did not deny that the workers had served them for several years. Therefore, they were regular employees, merely on leave during the off-season, and entitled to security of tenure.
2. On the issue of illegal dismissal and unfair labor practice: The Court upheld the factual findings of the NLRC, as affirmed by the CA, that the workers persistently sought to return to work and were illegally dismissed. The NLRC’s finding of unfair labor practice by petitioners, done in bad faith, justified the award of moral and exemplary damages. The Court emphasized that factual findings of labor tribunals, when supported by substantial evidence, are accorded respect and finality.