The Supreme Court denied the petition of a group of tobacco workers who sought to be declared regular employees of Universal Leaf Philippines, Inc. (ULPI) and to be paid money claims and damages, ruling instead that they were regular seasonal employees who were not illegally dismissed.
In its decision in G.R. No. 272080, the Court affirmed the Court of Appeals (CA), which had upheld the rulings of the National Labor Relations Commission (NLRC) and the Labor Arbiter dismissing the workers' complaints for lack of merit.
The Case
The case stemmed from Consolidated Complaints for Illegal Lay-off and Non-Payment of Salaries, Overtime Pay, 13th Month Pay, Service Incentive Leave Pay, Holiday Pay, and Allowances filed by Gilbert Rivera and others (Rivera et al.) against ULPI and its President Winston P. Uy.
In their Pinag-Samang Sinumpaang Salaysay, Rivera et al. alleged they were employed by ULPI as forklift operators, drivers, helpers, loading and unloading crew, carpenters, sweepers, and payloader and backhoe operators on various dates from 2005 to 2017. They said they were told they were seasonal employees, meaning there would be months when they were considered laid off and months when they would continuously render services. After each lay-off, ULPI would rehire them as new employees.
They also claimed that regular employees took over their tasks whenever they were laid off, and that while regular employees received clothing, laundry, medical, and rice allowances, leave benefits, and bonuses, Rivera et al. received only minimum pay without benefits.
ULPI and Uy explained that ULPI is a domestic company engaged in planting, processing, and trading tobacco locally and for export. Its business operations are divided into Growing Operations and Internal Operations, both of which are seasonal. The tobacco planting season takes place from October to April, while the bulk of the work of the Internal Operations mostly takes place during the months of April to December. ULPI and Uy admitted that Rivera et al. were hired for ULPI's Internal Operations and assigned to the GLL, Engineering, TMG, and Finished Goods Departments.
The Issue
The Court addressed whether Rivera et al. should be deemed regular employees of ULPI, and whether they were illegally dismissed.
The Ruling
The Court held that Rivera et al. failed to support their claim that they should be considered regular employees of ULPI by substantial evidence, and found no reason to disturb the uniform finding of the Labor Arbiter and the NLRC, affirmed by the CA, as to the nature of their employment.
The Court also agreed with the CA that Rivera et al. were not illegally laid off. Their failure to present evidence that they were completely separated from service after their last temporary lay-off negated their claim of illegal dismissal.
The dispositive portion reads: "FOR THESE REASONS, the Petition for Review on Certiorari is DENIED. The Decision, dated September 19, 2023, and the Resolution, dated February 6, 2024, of the Court of Appeals in CA-G.R. SP No. 166822, are AFFIRMED."
By the Numbers
- G.R. No. 272080
- Workers hired on various dates from 2005 to 2017
- Tobacco planting season: October to April
- Internal Operations bulk of work: April to December
- CA Decision dated September 19, 2023, and Resolution dated February 6, 2024
- NLRC Decision dated November 27, 2019, and Resolution dated March 13, 2020
- Labor Arbiter Eduardo D. Carpio's Decision dated June 21, 2019
The Court's Reasoning
The Court noted that the production of tobacco products involves multiple processes extending over several months, occurring in different locations and overlapping with one another. To ensure smooth and efficient operations, ULPI had to allocate Rivera et al. to various processes as each department became active and temporarily laid them off in a staggered manner when work was unavailable. Because the departments had different peak periods, this explained the varying schedules of their temporary layoffs.
The Court said that being hired for various periods over several years did not negate their status as regular seasonal employees, citing that in Abasolo, workers were considered regular seasonal employees despite performing services for over 20 years, since their work was only during tobacco seasons.
The Court further agreed that Rivera et al.'s admissions in their Pinag-Samang Sinumpaang Salaysay, as well as the stipulations of the Seasonal Employment Agreements they freely signed, showed they were properly informed of their engagement as seasonal workers.
On the dismissal claim, the Court held that the Seasonal Employees Recall to Work Notice and Seasonal Employees Temporary Layoff to Work Notice were conclusive evidence that Rivera et al. were considered on leave and did not lose their employment. ULPI itself recognized that they have security of tenure. As a consequence, their claims for allowances, benefits, moral and exemplary damages, and attorney's fees, premised on their assertion of illegal dismissal, were denied.
Source: Supreme Court decision in G.R. No. 272080, penned by Associate Justice Singh.
This report summarizes a public Supreme Court decision and is not legal advice.