GR 211263; (August, 2015) (Digest)
G.R. No. 211263, August 05, 2015
OKS DESIGNTECH, INC. REPRESENTED BY ZAMBY O. PONGAD, PETITIONER, VS. MARY JAYNE L. CACCAM, RESPONDENT.
FACTS
Petitioner OKS DesignTech, Inc. hired respondent Mary Jayne L. Caccam as an accountant under a Contract of Employment for a Fixed Period from January 21, 2008 to June 21, 2008. The contract was renewed for the period June 22, 2008 to June 21, 2009. On June 8, 2009, respondent received a letter dated June 6, 2009 informing her of the expiration of her contract on June 21, 2009 and giving her the option to consume her unused leave credits. Claiming illegal dismissal, respondent filed a complaint. The Labor Arbiter (LA) ruled in favor of respondent, declaring her a regular employee illegally dismissed and awarding backwages, separation pay, damages, and attorney’s fees. The National Labor Relations Commission (NLRC) reversed the LA, finding that respondent was a fixed-term employee whose contract simply expired. The Court of Appeals (CA) reinstated the LA’s decision, ruling that respondent was a regular employee illegally dismissed.
ISSUE
Whether the Court of Appeals erred in ruling that the NLRC gravely abused its discretion in finding that respondent was not a regular employee and was validly dismissed due to the expiration of her fixed-term contract.
RULING
The Supreme Court granted the petition and reversed the CA decision. The Court ruled that the NLRC did not gravely abuse its discretion. The Court held that respondent was a fixed-term employee, not a regular employee. The contracts clearly stipulated a fixed period of employment, and respondent never contested their fixed-term nature. The fact that her work was necessary and desirable to the petitioner’s business does not automatically confer regular status when the employment is for a specific undertaking with a clear timeframe agreed upon by the parties. The termination was due to the expiration of the contract, not a dismissal. The letter dated June 6, 2009 was a mere notice of the contract’s impending expiration. Consequently, there was no illegal dismissal.