Phil Federation of Credit Cooperatives, Inc.

vs NLRC RULING:
G.R. No. 121071 – December 11, 1998
TOPIC: Termination of Employment – General Concepts – Extension
DOCTRINE:
Regardless of the designation an employer may have conferred upon the
worker’s employment status, where the employee has completed the
probationary period and allowed to work thereafter, he becomes a regular
employee, and a dismissal premised on an alleged expiration of the contract
is illegal.
- Regardless of the designation an employer may have conferred upon
the worker’s employment status, where the employee has completed
the probationary period and allowed to work thereafter, he becomes a
regular employee, and a dismissal premised on an alleged expiration
of the contract is illegal.
- Because Abril was allowed to work after the end of her probationary
period of 6 months, she is deemed to have attained regular status and
is entitled to the security of her tenure.

FACTS:

- Victoria Abril was employed by Philippine Federation of Credit

Cooperatives, Inc. (PFCCI) on several occasions for certain periods:
o In 1982, as junior auditor/field examiner
o In 1985, as officer secretary
o In 1988, as cashier-designate for 4 months.
- Subsequently, she went on leave until she gave birth to a baby girl.
- Upon her return, she discovered that a certain Vangie Santos had
been permanently appointed to her former position. She,
nevertheless, accepted another position, the position of Regional
Field Officer, wherein she was put on a 6 months probation period.
- When the probation period ended, she was allowed to work until the
PFCCI presented to her another employment contract that was good
for 1 year.
- At the end of the 1 year period, she was terminated. She then filed
for illegal dismissal against PFCCI.
- PFCCI argued that Victoria served the company as a mere project
employee considering that she was employed to perform work
related to a project funded by the World Council of Credit Unions
(WOCCU). As such, she was legally dismissed when the term of the
contract expired.
- LA: Dismissed the complaint.
- NLRC: Reversed.

ISSUE:

Whether or not Abril was illegally dismissed. – YES.