G.R. No. 159343 September 28, 2007
PEDY CASERES and ANDITO PAEL, Petitioners, vs. UNIVERSAL ROBINA SUGAR MILLING CORPORATION (URSUMCO) and/or RESIDENT MANAGER RENE CABATE, Respondents.

FACTS

Petitioners Pedy Caseres and Andito Pael were hired by respondent Universal Robina Sugar Milling Corporation (URSUMCO) in 1989 and 1993, respectively. At the start of their employment, they signed a Contract of Employment for Specific Project or Undertaking. Their contracts were renewed periodically until May 1999, when they were informed that their contracts would no longer be renewed. Consequently, petitioners filed a complaint for illegal dismissal, regularization, and monetary claims.
The Labor Arbiter dismissed the complaint, a decision affirmed by the National Labor Relations Commission (NLRC) and subsequently by the Court of Appeals (CA). The lower tribunals uniformly held that petitioners were project employees and not regular employees, and thus were not illegally dismissed when their fixed-term contracts ended. Petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

The core issues were: (1) whether petitioners were seasonal/project employees or regular employees of the respondent; and (2) whether they were illegally dismissed and entitled to backwages and other monetary benefits.

RULING

The Supreme Court denied the petition and affirmed the rulings of the lower tribunals. The Court emphasized that a petition under Rule 45 should raise only questions of law. The determination of whether an employee is a project employee or a regular employee is a question of fact. The factual findings of the Labor Arbiter, NLRC, and CA, being consistent and supported by evidence, are binding on the Supreme Court absent any showing of grave abuse of discretion.
Applying Article 280 of the Labor Code, the Court distinguished between regular and project employees. A project employee is one whose employment is fixed for a specific project or undertaking, the completion of which is determined at the time of engagement. The Court found that petitioners were hired for specific phases of work or projects in the sugar milling industry, which has a cyclical off-milling season. Their contracts clearly indicated the temporary nature of their engagements. The repeated re-hiring did not automatically convert their status to regular employees, as the re-engagement was due to the recurring but distinct needs of the respondent’s seasonal operations. Therefore, their employment legally terminated upon the completion of the specific projects for which they were hired, constituting no illegal dismissal.