HACIENDA SAN ISIDRO / SILOS FARMS AND REY SILOS LLAMADO, PETITIONERS, VS. LUCITO VILLARUEL AND HELEN VILLARUEL, RESPONDENTS.
- G.R. Number: G.R. No. 220087
- Promulgated: 2025-08-11
- Ponente: ROSARIO, J.
Doctrine
## Facts of the Case Petitioners Hacienda San Isidro / Silos Farms and Rey Silos Llamado filed a Motion for Reconsideration of the Supreme Court's November 13, 2023 Decision, which initially deemed respondent Helen Villaruel a regular seasonal employee. The petitioners contended that Helen was not their regular employee primarily because they lacked control over the manner she performed her work and because she was free to contract her services to other employers. They also argued that the Court erred in ruling that **Mercado, Sr. v. NLRC** was inapplicable, asserting that **Hacienda Fatima** failed to distinguish between employees hired 'on and off' and those hired 'repeatedly for the same phase/s' of agricultural work. The lower tribunals (Labor Arbiter, NLRC, and CA) had initially conflicting, but ultimately uniform, findings that Helen was a regular employee. ## Issues 1. Did the Supreme Court err in its previous finding that respondent Helen Villaruel was a regular employee, particularly regarding the application of the control test? ## Decision / Rationale **Issue 1:** The Supreme Court **granted the Motion for Reconsideration**, reversed its previous decision, and held that respondent Helen Villaruel was not proven to be a regular employee. The Court upheld its doctrine on regular seasonal employment but modified its ruling regarding the factual finding of the existence of the power or right to control. While the issue of control is generally factual and beyond a Rule 45 petition, exceptions apply when the judgment is based on a misapprehension of facts or lacks substantial evidence. The Court found that despite the uniform findings of the lower tribunals (LA, NLRC, CA) that Helen was a regular employee, these findings were not supported by substantial evidence. The Court clarified its previous rulings: * It maintained that **Hacienda Fatima** did distinguish between workers hired regularly and repeatedly for the same phases of agricultural work and those hired on and off for any single phase. * It clarified that **Mercado, Sr.** did not make the freedom to contract services elsewhere the primary reason for denying regular employee status, but rather focused on the workers being hired on an on-and-off basis. * The Court found that the appellate court and labor tribunals failed to properly apply the control test. While **Gapayao v. Fulo** correctly stated the control test (right to control both the end and the means), it incompletely applied it by only focusing on the right to control the result without explicitly finding the right to control the **manner and means** of work. * Respondent Helen Villaruel failed to prove by substantial evidence that petitioners controlled or had the right to control the manner and means by which she performed her work. The lower tribunals’ findings, which relied on the nature of work, length of service, repeated assignment of tasks, and receipt of wages, were deemed insufficient to establish the employer-employee relationship under the control test. * The Court reiterated that Article 295 (now 295) of the Labor Code should not be used as the criterion to determine the existence of an employer-employee relationship when it is in dispute, as it merely distinguishes types of employment for benefit purposes. The Court concluded that the CA seriously erred in failing to impute grave abuse of discretion on the part of the NLRC given the absence of substantial evidence supporting its findings. ## Doctrines - **Regular Seasonal Employee:** A seasonal employee is deemed a regular employee if they perform work or services that are seasonal in nature, and they are employed to perform such work or services for more than one season. - **Pakyaw Scheme and Regular Employment:** Being compensated under a pakyaw scheme does not negate regular employment so long as the employer has the right to exercise the power of control or supervision over the performance of an employee's duties, regardless of whether…
Keywords
Rule 45 Rules of Court, Article 295 Labor Code, control test, regular seasonal employee doctrine, social justice in labor cases, employer-employee relationship, seasonal employment, labor dispute, petition for review on certiorari, substantial evidence, pakyaw scheme, pro forma motion, ratio decidendi, four-fold test, security of tenure, grave abuse of discretion, misapprehension of facts, motion for reconsideration granted, decision set aside, petition granted