Skip to main content

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 .

Labels:

Popular posts from this blog

People vs. Jugueta, 788 SCRA 331, G.R. No. 202124 April 5, 2016

G.R. No. 202124. April 5, 2016. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IRENEO JUGUETA, accused-appellant. PONENTE:  PERALTA, J.:  Synopsis: In Criminal Case No. 7702-G, Irenneo Jugueta was charged with Multiple Attempted Murder along with Gilbert Estores and Roger San Miguel. However, Roger San Miguel moved for reinvestigation of the case and was eventually dismissed, leaving Irenneo as the only defendant. The prosecution's witness, Norberto, testified that Irenneo and the two other men entered his family's nipa hut and fired shots, causing the death of one daughter and injury to another. Irenneo offered a defense of denial and alibi, but this was found to be weak by the trial court, which ruled that Irenneo conspired with the two other men to shoot the family of Norberto. The trial court's judgment was affirmed by the Court of Appeals. The main issue raised in the appeal was the inconsistencies in Norberto's testimony, but these were deemed to be trivial an...
Read more

Nagkakaisang Maralita ng Sitio Masigasig, Inc. v. Military Shrine Services, et. al. | G.R. No. 187587| 2013

G.R. No. 187587| June 5, 2013  697 SCRA 359 Nagkakaisang Maralita ng Sitio Masigasig, Inc. vs. Military Shrine Services-Philippine Veterans Affairs Office, Department of National Defense; NMSI , Petitioner, vs. MSS - PVAO, DND,  Respondent; ---and--- G.R. No. 187654| June 5, 2013 WBLOA, INC. , represented by its Board of Directors, Petitioner, vs.    MSS - PVAO, DND , Respondent. Ponente :  SERENO, CJ.:  Doctrines :  (1) Petitioners suggest that there should be no distinction between laws of general applicability and those which are not; that publication means complete publication; and that the publication must be made forthwith in the Official Gazette. (2) The requirement of publication is indispensable to give effect to the law, unless the law itself has otherwise provided.  (3) The Supreme Court cannot rely on a handwritten note that was not part of Proclamation No. 2476 as published. Without publication, the note never had any legal...
Read more

People vs. Dueño, 90 SCRA 23, No. L-31102 May 5, 1979

No. L-31102. May 5, 1979; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE DUEÑO, alias FELIPE CATALAN, SOFRONIO DUEÑO and ANDRESITO BELONIO alias HAPON, defendants-appellants. DOCTRINES: Appellants’ contention that the testimonies of the eyewitnesses Dellomos and Dolfo are inherently improbable as not be credible has been successfully traversed by the Solicitor General. For, Dolfo and Dellomos, having been the target of accused-appellants only a few hours earlier in the afternoon of the same day, may and should be expected to take some risks—to the point perhaps of being illogical and reckless—to identify and, if possible, frustrate any further attempts on the part of the three accused to assault and to try to kill them again. Motive is relevant where the indentity of the persons accused of having committed the crime is in dispute, where there are no eyewitnesses, and where suspicion is likely to fall upon a number of persons (People vs. Portugueza, L-22604, July 31, 1967...
Read more