G.R. No. 264439 , February 26, 2024
Ramon O. Sampana, Petitioner, vs. The Maritime Training Center of the Philippines, Captain Alejandro C. Aquino, Jr., and Normandy E. Gualberto, Respondents.

FACTS

Petitioner Ramon O. Sampana was engaged by respondent Maritime Training Center of the Philippines under a series of 17 contracts, initially denominated as “Consultancy Agreements” and later as “Employment with a Fixed Term,” from 2011 to 2016. His services were as an instructor. Petitioner expressed his intent to avail of optional retirement in writing to respondents on two occasions, but received no response. Subsequently, his employment was terminated through the non-renewal of his contract.

ISSUE

Whether the petitioner, engaged under successive fixed-term contracts, is a regular employee entitled to security of tenure and, consequently, to optional retirement benefits and other reliefs due to illegal dismissal.

RULING

The Concurring Opinion agrees with the ponencia’s ruling that the petitioner is a regular employee under a fixed-term contract. The successive renewals of his contracts over several years demonstrate that his services as an instructor were necessary and desirable to the respondents’ business, warranting regular status retroactive to the start of his engagement in 2011. Having fulfilled the five-year requirement, he was entitled to optional retirement. The respondents’ refusal to grant this benefit and their termination of his employment via non-renewal constituted illegal dismissal. The Opinion further emphasizes the constitutional protection of security of tenure and the power imbalance in employment relationships, justifying a high degree of judicial scrutiny over employment contracts. It concludes that the petitioner, despite his qualifications, was at the mercy of the respondents, who used fixed-term contracts to preclude security of tenure and denied his retirement rights. For these violations, he should be awarded damages in addition to backwages, retirement benefits, and attorney’s fees.