G.R. No. 167714 ; March 7, 2007
Rowell Industrial Corporation, Petitioner, vs. Hon. Court of Appeals and Joel Taripe, Respondents.

FACTS

Petitioner Rowell Industrial Corporation (RIC), a manufacturer of tin cans, employed respondent Joel Taripe as a rectangular power press machine operator on November 8, 1999. On February 17, 2000, Taripe filed a complaint for regularization and holiday pay, later amended to include illegal dismissal after RIC terminated his employment on April 6, 2000. RIC contended that Taripe was a contractual employee hired due to increased seasonal demand for packaging during the Christmas period and that his fixed-term contract had already expired on March 6, 2000. The Labor Arbiter dismissed Taripe’s complaint, finding him to be a contractual employee whose contract merely expired.
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision. The NLRC ruled that Taripe was a regular employee who had been illegally dismissed, ordering his reinstatement with full backwages. RIC’s motion for reconsideration was denied. RIC then filed a Petition for Certiorari with the Court of Appeals, which affirmed the NLRC’s ruling with modifications, exonerating the general manager from personal liability and clarifying the computation of backwages. RIC elevated the case to the Supreme Court via a Petition for Review.

ISSUE

The primary issue is whether respondent Joel Taripe was a regular employee or a legitimate contractual employee, and consequently, whether his dismissal was illegal.

RULING

The Supreme Court denied the petition and affirmed the rulings of the Court of Appeals and the NLRC, holding that Taripe was a regular employee illegally dismissed. The Court applied Article 280 of the Labor Code, which defines regular employment as either where the employee is engaged in activities necessary or desirable in the usual business of the employer, or where the employment has continued for more than one year. The nature of Taripe’s work as a machine operator was deemed necessary and desirable to RIC’s manufacturing business, making him a regular employee from day one, regardless of any contract labeling him as “contractual.”
The Court rejected RIC’s claim of seasonal demand, noting that the production of tin cans was a regular part of its business operations, not a specific seasonal activity. The fact that Taripe signed a contract did not override the legal presumption of regular employment established by the nature of his duties. Since RIC failed to prove a valid cause for termination under Articles 282, 283, or 284 of the Labor Code, and did not observe due process, the dismissal was illegal. The orders for reinstatement and payment of full backwages were upheld as proper remedies.