G.R. No. 228407 , June 10, 2020
JULIAN TUNGCUL TUPPIL, JR., DIOSDADO D. BATERNA, NICANOR M. MAPA, DEMETRIO B. BAU TISTA, JR., NORBERTO Y. NAVARRO, MARLO A. MERCED, ROLDAN P. RAMACULA, RAYMUND E. ALENTAJAN, FERDINAND M. HOSANA, ROEL SOLIS, RICARDO D. FLORES, LARRY T. BORJA, RIZALDY S. DE LEON, RICO D. ESPEÑA, MARCOS L. VASQUEZ, ZALDY V. PEDRO, JOSEPH R. REYES, AND ARIEL S. RAMOS, PETITIONERS, VS. LBP SERVICE CORPORATION, RESPONDENT.

FACTS

LBP Service Corporation (LBPSC) entered into a manpower services agreement with Land Bank of the Philippines and deployed petitioners as janitors, messengers, and utility persons to various Land Bank branches in Metro Manila. In 2014, the contract between LBPSC and Land Bank expired, leading LBPSC to issue notices of recall to the affected employees. Upon receipt, one group of petitioners (Tuppil, et al.) submitted resignation letters. Subsequently, all petitioners filed a complaint for illegal dismissal against LBPSC before the Labor Arbiter, claiming they were regular employees performing necessary and desirable services. LBPSC countered that the recalled workers were to be reassigned and that Tuppil, et al. voluntarily resigned. The Labor Arbiter dismissed the complaint, ruling petitioners were fixed-term contractual employees, no termination occurred, and Tuppil, et al. voluntarily resigned. The NLRC and the Court of Appeals affirmed these findings.

ISSUE

Whether the Court of Appeals committed serious error in affirming the findings of the NLRC and Labor Arbiter that petitioners were fixed-term contractual employees and were not illegally dismissed.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The Court held that contracts of employment for a fixed term are valid unless imposed to circumvent security of tenure laws. Citing Pure Foods Corporation v. NLRC, the Court reiterated the criteria for a valid fixed-term employment: (1) the fixed period was knowingly and voluntarily agreed upon without force or vitiated consent, or (2) the parties dealt on more or less equal terms. Petitioners’ employment contracts expressly stipulated that their employment would end upon the non-renewal of LBPSC’s contract with Land Bank, and there was no evidence of pressure or unequal bargaining power. The fact that employees perform necessary and desirable activities does not prohibit a fixed-term contract. Consequently, the termination of petitioners’ services upon the expiration of the LBPSC-Land Bank contract was not illegal dismissal, as fixed-term contracts terminate automatically at the end of the period. Regarding Tuppil, et al., the Court found their resignations voluntary, as evidenced by their resignation letters expressing gratitude and their subsequent employment with another agency. The Court declined to re-evaluate factual findings, noting the consistent conclusions of the Labor Arbiter, NLRC, and Court of Appeals, and found no grave abuse of discretion.