GR 86408; (February, 1990) (Digest)
G.R. No. 86408 February 15, 1990
BETA ELECTRIC CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER CRESENCIO INIEGO, BETA ELECTRIC EMPLOYEES ASSOCIATION, and LUZVIMINDA PETILLA, respondents.
FACTS
Petitioner Beta Electric Corporation hired private respondent Luzviminda Petilla as a clerk typist under a series of fixed-term employment contracts from December 15, 1986. Her initial contract was until January 16, 1987, and she received successive extensions, each documented in writing, culminating in a final extension until June 30, 1987. However, on June 22, 1987, prior to the expiry of her last contract, her services were terminated without notice or hearing. Petilla immediately filed a complaint for illegal dismissal.
The Labor Arbiter ruled in favor of Petilla, ordering her reinstatement with backwages. The National Labor Relations Commission (NLRC) affirmed this decision. The petitioner corporation appealed to the Supreme Court, arguing that Petilla was merely a temporary employee hired to meet peak business demands and that her fixed-term contracts legally permitted termination upon contract expiry.
ISSUE
The core issue is whether the series of fixed-term employment contracts rendered Petilla a temporary employee who could be terminated at the end of a contract period, or whether she attained the status of a regular employee entitled to security of tenure.
RULING
The Supreme Court dismissed the petition and affirmed the NLRC decision, ruling that Petilla was illegally dismissed and had attained regular employment status. The legal logic centers on the application of Article 280 (now Article 295) of the Labor Code, which defines regular and casual employment. The Court rejected the petitioner’s claim that the contract-to-contract arrangement created a legitimate temporary employment. It held that the nature of Petilla’s work as a clerk typist was “usually necessary or desirable in the usual business or trade of the employer,” which is the statutory definition of regular employment.
Crucially, the Court ruled that the successive contracts, spanning over six months from December 15, 1986, to June 22, 1987, could not supersede the mandate of the Labor Code. By operation of law, Petilla, who was allowed to work after a probationary period of six months, became a regular employee. The contractual stipulations were deemed an artifice to circumvent her security of tenure. The work was not for a specific project or seasonal undertaking as defined by law but was integral to the company’s ordinary operations. Therefore, her dismissal without just or authorized cause and without due process was illegal. The Court ordered her reinstatement with three years of backwages without qualification or deduction.