GR 240774; (March, 2021) (Digest)
G.R. No. 240774 , March 03, 2021
TOYO SEAT PHILIPPINES CORPORATION/YOSHIHIRO TAKAHAMA, PETITIONERS, VS. ANNABELLE C. VELASCO, RENATO NATIVIDAD, FLORANTE BILASA, AND MARY ANN BENIGLA, RESPONDENTS.
FACTS
Petitioner Toyo Seat Philippines Corporation (TSPC) is a corporation engaged in manufacturing car seats and related products. Respondents were hired by TSPC as sewers in 2008 and 2009 for specific projects: initially for Project J68C (Export Trim for 2008 Mazda 3), then for Project J68N (Export Trim for 2011 Mazda 3) under a Project Employment Contract from June 8, 2011, to December 20, 2012. Due to low order volumes for the J68N Project, respondents were also assigned to work on Project GS41 (Export Trim/Seats for Mitsubishi Lancer) on an alternating schedule. The J68N Project was extended until June 30, 2013, and then for one more week until July 12, 2013. Respondents declined the final extension, believing they had attained regular employee status, and filed a complaint for regularization with the NLRC in April and May 2013. Consequently, TSPC informed them that their project employment ceased effective July 1, 2013, converting their complaint into one for illegal dismissal. The Labor Arbiter dismissed the complaint, ruling respondents were valid project employees. The NLRC affirmed this. The Court of Appeals reversed, declaring respondents regular employees and ordering their reinstatement with full backwages and damages.
ISSUE
Whether or not the respondents were project employees and were legally dismissed.
RULING
The Supreme Court granted the petition, reversed the Court of Appeals Decision and Resolution, and reinstated the NLRC Decision which affirmed the Labor Arbiter’s dismissal of the complaint. The Court ruled that respondents were legitimate project employees, not regular employees. Their employment was fixed for specific projects (J68C, J68N, GS41) with determined periods, as stipulated in their contracts and supported by project-specific termination reports. The fact that their work as sewers was necessary and desirable to TSPC’s business did not automatically confer regular status, as project employment is recognized when the job is coterminous with a specific undertaking. The successive rehiring under different project contracts did not constitute regular employment, as each project was distinct, identifiable, and not within TSPC’s regular business cycle. Their dismissal was legal, occurring upon the project’s completion and their refusal of a valid extension offer. The requirement to submit termination reports under Department Order No. 19 applies only to the construction industry, not to TSPC’s manufacturing business.