**Facts:**
The case stemmed from a complaint filed on July 19, 1999, by Carlos Pabriga, Geoffrey Arias, Kirby Campo, Arnold Laganit, and Armand Catubig against their employer GMA Network, Inc. They contested their working conditions and alleged violations regarding their employment status. They performed tasks central to GMA Network, Inc.’s operations, including manning the Technical Operations Center, acting as Transmitter/VTR men, Maintenance staff, and Cameramen. Following the filing of the complaint, they experienced confrontations with management and were barred from work. Their request to be recalled to work received no response regarding their employment status. The Labor Arbiter initially dismissed their claims for illegal dismissal and unfair labor practice but held GMA liable for 13th month pay. The National Labor Relations Commission (NLRC) reversed this, recognizing them as regular employees entitled to various compensations, a decision affirmed by the Court of Appeals and further contested by GMA Network, Inc.
**Issues:**
1. Whether respondents are regular employees or project employees.
2. Whether respondents were illegally dismissed.
3. Whether respondents are entitled to separation pay, night shift differential, and attorney’s fees.
**Court’s Decision:**
1. The Supreme Court affirmed the findings of the NLRC and the Court of Appeals, ruling that the respondents are regular employees, not project or fixed-term employees, based on the nature and necessity of their work in the usual business of the employer.
2. Since GMA Network, Inc. failed to prove a just or authorized cause for termination, the Court declared that the respondents were illegally dismissed.
3. The Court affirmed their entitlement to separation pay in lieu of reinstatement and night shift differential, but it deleted the award for attorney’s fees due to lack of express factual, legal, or equitable justification for such an award in the text of the decision.
**Doctrine:**
– The nature of employment is determined by law regardless of any contract expressing otherwise, aiming to afford full protection to labor.
– A project employee is one engaged for a specific project or undertaking, the duration and scope of which are specified at the time of engagement.
– Regular employment is deemed when the employee performs activities usually necessary or desirable in the usual business or trade of the employer.
– Continuous rehiring of project employees may result in them attaining the status of regular employees.
**Class Notes:**
– Regular Employees: Perform activities necessary or desirable in the employer’s business and are entitled to security of tenure.
– Project Employees: Assigned to a specific project with a determined duration, not covered by the usual activities of the business.
– Illegal Dismissal: Termination of employment without just cause or due process.
– Separation Pay: Compensation due to employees in lieu of reinstatement when the employment relationship has become strained.
– Night Shift Differential: Additional compensation for work performed between 10 PM and 6 AM.
**Historical Background:**
This case illustrates the Supreme Court’s role in interpreting labor laws to protect workers’ rights in the Philippines. It emphasizes the Court’s commitment to upholding the constitutional mandate of providing full protection to labor, highlighting the principle that the determination of employment status is governed by law over and above the agreements set by parties, aimed at preventing circumvention of statutory protections for workers, particularly regarding security of tenure and regular employment.
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