GR 164315; (July, 2009) (Digest)
G.R. No. 164315 ; July 3, 2009
ALCATEL PHILIPPINES, INC., and YOLANDA DELOS REYES, Petitioners, vs. RENE R. RELOS, Respondent.
FACTS
Petitioner Alcatel Philippines, Inc., a company engaged in installing telecommunications equipment, hired respondent Rene R. Relos for various temporary positions starting in 1988. His initial contracts were for specific, short-term projects like the PLDT X-5 and X-4 IOT projects. In 1991, he was hired as a Civil Works Inspector for the PLDT 1342 project, with his employment repeatedly renewed through a series of fixed-term contracts until December 31, 1995. Upon the project’s completion, Alcatel informed Relos that his contract was expiring.
In 1997, Relos filed a complaint for illegal dismissal, claiming he was a regular employee dismissed during the project’s existence. The Labor Arbiter ruled in his favor, declaring him a regular employee and ordering his reinstatement with back wages. The National Labor Relations Commission (NLRC) reversed this, finding him to be a project employee whose employment ended lawfully upon the contract’s expiration. The Court of Appeals then reinstated the Labor Arbiter’s decision, prompting Alcatel’s appeal to the Supreme Court.
ISSUE
Whether or not respondent Rene R. Relos was a project employee, and consequently, whether his termination upon the completion of his project-based contract constituted illegal dismissal.
RULING
The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the NLRC decision. The Court held that Relos was a project employee, not a regular employee. The legal logic centered on the nature of project employment under Article 280 of the Labor Code. A project employee is one whose work is coterminous with a specific project or undertaking, the completion or termination of which has been determined at the time of engagement.
The Court found that Relos was hired for a specific undertaking—the PLDT 1342 project. His successive employment contracts, from February 1991 to December 1995, all stipulated fixed periods and were explicitly for that singular project. The fact of being repeatedly re-hired within the same, ongoing project did not convert his status to regular employment. His work was necessary only for the duration of that particular project. The termination of his employment on December 31, 1995, was due to the bona fide completion of the project as stipulated in his contract, not an illegal dismissal. Therefore, his employment legally ended upon the expiration of his contract, and he was not entitled to reinstatement or back wages.