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ABUDA, et al v. L. NATIVIDAD POULTRY FARMS, JULIANA NATIVIDAD, and MERLINDA NATIVIDAD. G.R. No. 200712 | 2018

Case Digest: G.R. No. 200712 | July 4, 2018

Mario A. Abuda, et al. vs. L. Natividad Poultry Farms, et al.

Ponente: Justice Leonen

Nature of the Petition

This is a Petition for Review filed by multiple workers against L. Natividad Poultry Farms, assailing the October 11, 2011 Decision and February 8, 2012 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 117681. The case concerns the workers’ claims for illegal dismissal, unfair labor practice, backwages, and other monetary awards.

Court Ruling

The Supreme Court REMANDED the case to the Labor Arbiter for the computation of backwages and other monetary awards due to the petitioners.

Key Doctrines

✔️ Regular Employment & Length of Service: An employee who has worked for at least one year is considered a regular employee under the Labor Code. The necessity or desirability of the work performed can be inferred from the duration of service.

✔️ Employment Classification & Business Necessity: In De Leon v. National Labor Relations Commission, the Supreme Court ruled that regular employment is determined by examining the connection between the worker’s tasks and the employer’s business. Even if work is intermittent, a continuous and repeated need for the worker’s services affirms their indispensability.

✔️ Labor-Only Contracting & Employer Liability: If third-party labor contractors function as mere agents, rather than as legitimate independent contractors, the primary employer remains liable for employment violations.

Case Background

The petitioners, workers from L. Natividad Poultry Farms, filed complaints for:

  • Illegal dismissal

  • Unfair labor practice

  • Overtime pay

  • Holiday pay & premium pay

  • Service incentive leave pay

  • Thirteenth-month pay

  • Moral & exemplary damages

Initial Dismissal & Appeal

  • The Labor Arbiter dismissed the case, ruling that no employer-employee relationship existed between the petitioners and L. Natividad.

  • On appeal, the National Labor Relations Commission (NLRC) found that the petitioners had been hired on a "pakyaw" basis through labor-only contractors to perform specific services for L. Natividad.

Court of Appeals (CA) Decision

  • The CA modified the NLRC ruling, declaring San Mateo General Services and Del Remedios as labor-only contractors—mere agents of L. Natividad Poultry Farms.

  • However, the CA still upheld that the petitioners were hired for intermittent repairs and maintenance, classifying them as non-regular employees.

Supreme Court’s Findings

  • The workers continuously worked for L. Natividad for 3 to 17 years, making their employment regular by operation of law.

  • Despite the CA’s opinion that carpentry and masonry work were not essential to poultry farming, the Court found that the petitioners' construction and repair activities were integral to L. Natividad's livestock and poultry operations.

  • The petitioners performed construction, facility repairs, and maintenance at L. Natividad's farms and sales outlets, proving their necessity in the business.

Conclusion

The Supreme Court ruled that the petitioners were regular employees and entitled to backwages and monetary awards. Their consistent service demonstrated indispensability to L. Natividad Poultry Farms, and they deserved protection from arbitrary dismissal.

For full case details, visit the .

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