GR 150478; (April, 2005) (Digest)
G.R. No. 150478. April 15, 2005
HACIENDA BINO/HORTENCIA STARKE, INC./HORTENCIA L. STARKE, Petitioners, vs. CANDIDO CUENCA, ET AL., Respondents.
FACTS
The petitioners own and operate Hacienda Bino, a sugar plantation. The 76 respondents were part of its workforce, performing various agricultural tasks. On July 18, 1996, petitioner Hortencia Starke issued a notice stating that only employees who did not sign in favor of coverage under the Comprehensive Agrarian Reform Program (CARP) would be given employment. The respondents, who had applied as CARP beneficiaries, construed this as a termination of their employment and filed a complaint for illegal dismissal and monetary claims.
Petitioners contended that work was seasonal and scarce during the off-milling period. They asserted that the notice merely reflected a preference for workers supporting the hacienda’s land reclassification and that the respondents were not dismissed but were offered work again when the season began, which they refused. The Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in favor of the respondents, declaring their dismissal illegal. The Court of Appeals affirmed this decision.
ISSUE
Whether the respondents were illegally dismissed from their employment.
RULING
Yes, the Supreme Court affirmed the finding of illegal dismissal. The Court held that the notice issued by Starke was a clear act of dismissal, conditioning employment on the workers’ withdrawal of support for CARP. This constituted a dismissal without just or authorized cause and without due process. The petitioners’ claim of seasonal employment and lack of work was unavailing.
The legal logic centered on the respondents’ status as regular employees. The Court reiterated that while the work in a sugar plantation may be seasonal, the employees are considered regular if they are engaged for tasks necessary and desirable in the usual business of the employer and are repeatedly rehired for such tasks over the years. The payrolls showed the respondents were engaged since 1991, proving they were not hired for one season only. As regular employees, they enjoy security of tenure. The burden to prove the legality of the dismissal rests on the employer, which the petitioners failed to discharge. The dismissal, being motivated by the employees’ exercise of their right to apply under CARP, was unlawful. The awards for reinstatement, backwages, and other monetary benefits were thus upheld.