**Facts:**
– **Employment and Duties:** On various dates from 2006 to 2010, the petitioners were employed by Philtranco Service Enterprises Inc. as bus drivers and/or conductors, operating routes from Manila to Bicol, Visayas, and Mindanao. They were paid P404.00 per round trip.
– **Filing of Complaint:** On July 4, 2011, the petitioners filed a complaint for regularization, underpayment of wages, non-payment of service incentive leave (SIL) pay, and attorney’s fees.
– **Respondents’ Defense:** Philtranco claimed the petitioners were on a pay rate of P0.49 per kilometer or minimum wage, whichever was higher, and asserted that the petitioners were seasonal employees or field personnel.
**Procedural History:**
1. **Labor Arbiter (LA) Decision (October 17, 2011):** The LA declared petitioners as regular employees but dismissed their claims for overtime and SIL pay, citing them as field personnel.
2. **NLRC Appeal (December 8, 2011):** Petitioners filed a partial appeal.
3. **NLRC Ruling (February 22, 2012):** The NLRC granted the appeal, awarding wage differentials, SIL pay, and overtime benefits for three years backwards from the date of filing.
4. **Motion for Reconsideration (March 12, 2012):** The respondents’ motion was denied by the NLRC on May 30, 2012.
5. **CA Petition for Certiorari (CA-G.R. SP No. 126210):** The respondents appealed to the CA.
6. **CA Decision (August 30, 2013)**: Reversed the NLRC’s decision, reinstated the LA’s decision, and nullified the execution actions taken by the NLRC’s sheriff.
7. **Petition for Review on Certiorari:** Filed by the petitioners to the Supreme Court.
**Issues:**
1. **Field Personnel Status:** Whether the petitioners, as bus drivers and conductors, should be classified as field personnel.
2. **Entitlement to Benefits:** Whether they were entitled to overtime pay and SIL pay.
**Court’s Decision:**
**Field Personnel Classification:**
1. **Field Personnel Analysis:** Based on the “Auto Bus Transport Systems, Inc. vs. Bautista” precedent, the Supreme Court noted that field personnel are characterized by a lack of supervision and hours that cannot be certainly determined. However, bus drivers and conductors have fixed routes and schedules, are under supervision through dispatchers and checkers, have determined work hours, and must adhere to specific times and routes.
2. **Ruling:** The SC sided with the NLRC, finding the petitioners as non-field personnel since they could be supervised and their work hours were ascertainable.
**Entitlement to Benefits:**
1. **Regular Status and Benefits:** Since the petitioners were regular employees, they were entitled to minimum wage, overtime pay, and SIL pay.
2. **Setting Aside CA Decision:** The SC reversed the CA’s decision and reinstated the NLRC’s decision that awarded the benefits claimed by the petitioners.
**Doctrine:**
– **Field Personnel Definition:** Employees are not field personnel if required to be at specific places at specific times and if their time and performance are supervised.
– **Employee Benefits:** Regular employees performing tasks necessary and desirable to the employer’s usual business are entitled to statutory employment benefits, including minimum wage, overtime pay, and service incentive leave pay.
**Class Notes:**
– **Employment Status:** Criteria for determining regular vs. field personnel.
– **Field Personnel Definition:** (Labor Code Articles and Doctrine) – Performance unsupervised, work hours indeterminable.
– **Employee Benefits:** Contesting work roles for entitlement to benefits.
**Historical Background:**
– **Scope and Definition Expansion:** This case furthers the understanding and application of what constitutes a “field personnel” under Philippine labor law, highlighting protective labor standards for similarly situated employees. This PhITranco case connects back to broader labor struggles concerning the status, working conditions, and rights of workers in the transportation sector. It underscores the judiciary’s role in ensuring statutory labor protections are upheld amidst evolving employment structures and industry practices.
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