G.R. No. 163033. October 02, 2009 (Case Brief / Digest)

**Title:** San Miguel Corporation vs. Eduardo L. Teodosio, G.R. No. 157766, October 1, 2008


Eduardo L. Teodosio was hired by San Miguel Corporation (SMC) on September 5, 1991, as a casual forklift operator in the Bacolod City Brewery. His main task was the loading and unloading of pallet beer cases. He worked continuously till March 1992, after which he was “asked to rest.” He was rehired a month later, again for four to six months, and then again asked to rest. After three weeks, he was rehired and continued till August 1993. In August 1993, he signed a “Employment with a Fixed Period” contract. This stipulated his employment from August 7, 1993, to August 30, 1995, or until market demand stabilized.

On March 20, 1995, Teodosio was transferred to the bottling section as a case piler. He opposed the transfer in a letter to SMC dated April 10, 1995, and requested to be returned to his position as a forklift operator. SMC did not respond. In June 1995, SMC informed Teodosio that his employment would terminate on July 1, 1995, due to reorganization. He expressed his dismay in a letter on July 3, 1995, indicating that acceptance of separation pay and signing a waiver did not mean waiving his right to question his dismissal. He accepted his separation pay and signed a Receipt and Release document, but immediately filed a complaint for illegal dismissal with the NLRC on July 4, 1995.

The Labor Arbiter dismissed Teodosio’s complaint, considering the fixed-term contract valid. The NLRC affirmed this decision; however, Teodosio filed a petition for certiorari with the Court of Appeals (CA). On October 30, 2003, the CA found that Teodosio was a regular employee before signing the fixed-term contract, declaring his transfer and dismissal invalid, and granted Teodosio back wages and reinstatement. SMC’s motion for reconsideration was denied, prompting the company to file a petition for review on certiorari with the Supreme Court.


1. Whether Teodosio was a regular employee of SMC.
2. Whether Teodosio was illegally dismissed.
3. Whether Teodosio is entitled to monetary claims and damages.
4. Validity of the Receipt and Release signed by Teodosio.
5. Whether the award for damages was proper.

**Court’s Decision:**

*First Issue:* Teodosio was deemed a regular employee as per Article 280 of the Labor Code, with necessary or desirable work and having served for a duration that indicates regularity. The Supreme Court found that Teodosio had been employed by SMC for 23 months, thus attaining regular employment status by September 1992 before signing the fixed-term contract.

*Second Issue:* Given the determination of his regular status, his dismissal based on the fixed-term contract was invalid. His transfer to the bottling section and subsequent termination lacked just or authorized cause, making his dismissal illegal.

*Third Issue:* As a consequence of the illegal dismissal, Teodosio was entitled to reinstatement without loss of seniority rights and back pay. Given the length of litigation and position of his replacement, separation pay was awarded in lieu of reinstatement.

*Fourth Issue:* The Receipt and Release executed by Teodosio did not bar the legal challenge due to his prior letter (July 3, 1995) indicating his intention not to waive his rights despite signing the document under compulsion.

*Fifth Issue:* The CA’s awarding of moral and exemplary damages was struck down due to insufficient proof of bad faith or malicious intent in his dismissal. Attorney’s fees were justified given the unlawful withholding of lawful wages.


1. **Regularization by Nature of Work and Duration of Service:** Regular status can be proved by activities integral to an employer’s usual business or through cumulative service length over a year.
2. **Invalid Fixed-Term Contracts:** Contracts designed to undermine the security of tenure of a regular employee are invalid.
3. **Right to Security of Tenure:** Ensuring employees are not dismissed without just or authorized cause.
4. **Release and Quitclaim:** The voluntariness and adequateness of consideration are critical in assessing their validity. They do not bar claims for illegal dismissal if not freely and voluntarily signed.

**Class Notes:**

1. **Regular Employment (Art. 280, Labor Code):** Defines regular and casual employment based on the nature of work and period of service.
2. **Security of Tenure (Labor Code):** Employee’s assurance against termination without just cause.
3. **Fixed-term Employment Contracts:** Validity can be questioned if intended to circumvent regular employment.
4. **Receipt and Release or Quitclaim Doctrine:** Generally disfavored if found executed under duress or without fair consideration (Philippine case law context).

**Historical Background:**

The decision reflects labor jurisprudence focused on protecting the workforce’s stability and rights, emphasizing the employee’s security of tenure amidst evolving labor dynamics. It revisits established doctrines about regular employment and contractual obligations, reaffirming principles to prevent exploitation through contractual circumventions by employers.


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