COOGEE INTERNATIONAL INC., PETITIONER, VS. DAVE B. MANINGO, JUSTINO E. PEREZ, ANTONINO G. QUIRANTE, CHRISTOPHER BRYAN R. MARTE, MIKE G. QUIRANTE, AND MARK KEMUEL B. HERNANDEZ, RESPONDENTS.
- G.R. Number: G.R. No. 264881
- Promulgated: 2025-07-16
- Ponente: GAERLAN, J.
Doctrine
## Facts of the Case Coogee International Inc. (Coogee), a construction company, hired Dave B. Maningo, Justino E. Perez, Antonino G. Quirante, Christopher Bryan R. Marte, Mike G. Quirante, and Mark Kemuel B. Hernandez (Maningo et al.) for its Manila Bay Project Mall (Project Mall) as safety crew, carpenter, and helper. Their Project Employment Contracts (PECs) stated that their employment would last until the completion of "structural works." On February 13, 2019, Maningo et al. received Notices of Project Completion, informing them that their services would end on February 20, 2019. Maningo et al. subsequently filed a complaint for illegal dismissal and monetary claims, arguing they were regular employees and that the Project Mall's structural works were still ongoing, evidenced by Coogee's continuous hiring of workers for the same. Coogee maintained that Maningo et al. were validly terminated due to the completion of the structural works, as stipulated in their PECs, and that it complied with DOLE reportorial requirements. The Labor Arbiter (LA) dismissed the illegal dismissal claim, finding Maningo et al. to be project employees whose contracts ended with project completion, but ordered Coogee to pay holiday and service incentive leave pay (SILP). The National Labor Relations Commission (NLRC) affirmed the LA's findings on project employment and valid termination but added attorney's fees. The Court of Appeals (CA) reversed, finding Maningo et al. illegally dismissed because Coogee failed to prove the specific structural works for which they were hired had been completed, and ordered reinstatement (or separation pay if impractical), backwages, holiday and SILP, nominal damages, and attorney's fees. Coogee then appealed to the Supreme Court. ## Issues 1. Whether the petition for certiorari before the CA should have been dismissed for Maningo et al.'s failure to attach Coogee's Answer. 2. Whether the CA erred in finding that Maningo et al. were illegally dismissed from employment. ## Decision / Rationale **Issue 1:** The Court held that the petition for certiorari before the CA should **not** have been dismissed. The Court clarified that only relevant and pertinent pleadings and documents need to be attached to a petition for certiorari. The **Air Philippines Corp. v. Zamora** case outlined guideposts indicating that not all pleadings and parts of case records are required, and omission may not warrant dismissal if the contents can be found in other attached documents or if the court can discern the merits without them. In this case, Coogee's Answer substantially reiterated arguments found in its Position Paper, which was attached to Maningo et al.'s petition. Therefore, the CA correctly determined that it could judiciously resolve the petition without the specific attachment of Coogee's Answer. **Issue 2:** The Court ruled that Maningo et al. were **illegally dismissed** from employment. The Court affirmed the uniform finding of the LA, NLRC, and CA that Maningo et al. were **project employees**. However, the Court agreed with the CA that Coogee failed to prove the validity of their termination. The burden is on the employer to establish that the dismissal was due to project completion. Coogee's submitted documents—Notices of Project Completion, Certificate of Final Acceptance, and Establishment Employment Report (EER)—were insufficient. The PECs engaged Maningo et al. for "structural works" generally, not specifically for "Lot 1, Phase 1 Structural Works" as indicated in Coogee's Certificate of Final Acceptance. Coogee failed to prove that Maningo et al. were assigned only to that specific phase which was allegedly completed. The Court also held that the accommodation letters, despite being photocopies and lacking affidavits, were admissible in labor cases due to relaxed evidentiary rules and were not denied by Coogee. These letters, showing Coogee hiring new workers for structural works around the time of Maningo et al.'s…
Facts
Coogee International Inc. hired Dave B. Maningo and others as project employees for the "structural works" of its Manila Bay Project Mall. On February 13, 2019, the employees received a Notice of Project Completion, effectively ending their services on February 20, 2019. The employees filed a complaint for illegal dismissal, claiming they were regular employees and that the project was still ongoing, as evidenced by Coogee continuing to hire workers for structural works. The Labor Arbiter and the NLRC sided with Coogee, but the Court of Appeals reversed the decision, finding the dismissal to be illegal.
Issues
1. Whether the Court of Appeals (CA) should have dismissed the petition for certiorari for failure to attach all relevant pleadings. 2. Whether the CA erred in finding that the employees were illegally dismissed.
Ruling
The Supreme Court denied the petition, affirming the CA's finding of illegal dismissal. The Court ruled that the CA did not err in giving due course to the petition as the omitted pleading's contents were substantially covered in another attached document. It held that while the respondents were project employees, the employer, Coogee, failed to prove that the specific project phase for which they were hired ('structural works') was actually completed at the time of termination. The evidence presented by Coogee, such as a Certificate of Final Acceptance for only 'Lot 1, Phase 1' and termination reports, was insufficient to prove the completion of the entire structural works, leading to the conclusion that the dismissal was without a valid cause.
Keywords
Rule 45 Rules of Court, Rule 46 Rules of Court Section 3, Rule 65 Rules of Court Section 1, Department Order No. 19 Series of 1993 Section 2.2, Department Order No. 19 Series of 1993 Section 3.3(b), Article 2208 Civil Code, Factual findings of the LA and NLRC when confirmed by the CA are conclusive, Burden to prove validity of termination of employment lies with the employer, Technical rules of evidence are not strictly applied in labor cases, Nominal damages cannot co-exist with actual or compensatory damages, Illegal dismissal, Project employment, Monetary claims, Labor dispute, Petition for Review on Certiorari, Project Employment Contracts, backwages, separation pay, holiday pay, service incentive leave pay (SILP)