G.R. No. 220087 , November 13, 2023
HACIENDA SAN ISIDRO/SILOS FARMS AND REY SILOS LLAMADO, PETITIONERS, VS. LUCITO VILLARUEL AND HELEN VILLARUEL, RESPONDENTS.

FACTS

Spouses Lucito and Helen Villaruel worked at Hacienda San Isidro, a sugarcane farm. They filed separate complaints for illegal dismissal and monetary claims. The Labor Arbiter found Helen to be a regular employee who was illegally dismissed, ordering payment of backwages and separation pay. The NLRC initially reversed this, finding no employer-employee relationship for Helen, but later reinstated the Labor Arbiter’s ruling on reconsideration. The Court of Appeals, upon petition, initially agreed with the NLRC’s first ruling, holding that Helen failed to prove the employer’s power of control, a key element of employment. However, upon Helen’s motion for reconsideration, the CA amended its decision, ultimately declaring her a regular seasonal employee.
The core dispute centered on Helen’s employment status. Petitioners argued she was not an employee but an independent contractor, free to work for others and paid on a pakyaw or piece-rate basis for specific, seasonal tasks like planting and harvesting sugarcane. They asserted a lack of control over her work. Helen contended she performed necessary and desirable work for the hacienda’s business for several years, making her a regular employee entitled to security of tenure.

ISSUE

Whether respondent Helen Villaruel is a regular employee of the petitioners.

RULING

Yes, Helen Villaruel is a regular seasonal employee. The Supreme Court affirmed the amended CA decision, applying established jurisprudence on seasonal employment in agriculture. The legal logic proceeds from Article 295 of the Labor Code and the controlling test of employment. A seasonal employee is deemed regular if they are hired for work that is seasonal in nature and are re-hired for such work for more than one season. The nature of the work being seasonal does not preclude regular status.
The Court clarified that the “power of control” test remains paramount. The fact that Helen was free to offer her services to others and was paid on a pakyaw basis does not automatically negate an employer-employee relationship. What is decisive is whether the employer retains the right to control the means and methods of accomplishing the work. The repeated hiring for the same necessary tasks in the hacienda’s sugar production over successive seasons demonstrates that her work was integral to the business. This repeated engagement satisfies the requirement of control, as the employer effectively dictates the need for her services each season. Consequently, as a regular seasonal employee illegally dismissed, Helen was correctly awarded backwages and separation pay. The ruling reinforces that labor law favors the determination of regular employment, especially when the work performed is necessary and desirable to the usual business of the employer, and the employment relationship extends beyond a single season.