Petitioner
Phil. Federation of Credit Cooperatives
Respondent
National Labor Relations Commission (First Division)
Citation
G.R. No. 121071
Court
Supreme Court
Division
Third Division
Ponente
Romero, J.
Decided
December 11, 1998

Summary

Victoria Abril worked for PFCCI in various capacities from 1982. In 1989, she accepted a Regional Field Officer position under a contract designating probationary status for six months. After completing the probationary period, she continued working and received another one-year contract before being terminated. The Supreme Court affirmed the NLRC ruling that Abril became a regular employee after working beyond the probationary period, regardless of subsequent contract designations. The Court emphasized that probationary employees who work beyond their probationary terms acquire regular status with security of tenure under Article 281 of the Labor Code. Contract ambiguities must be construed against the employer and in favor of the worker. The dismissal based solely on contract expiration was therefore illegal, entitling Abril to reinstatement and backwages. This case reinforces the principle that employment classification depends on the actual employment relationship rather than contractual labels.

Statutes applied

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By the Intellegal Editorial Board · December 11, 1998

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