Hacienda Bino/Hortencia Starke, Inc./Hortencia L. Starke vs. CANDIDO CUENCA, ET AL.

Agricultural workers engaged in activities that are seasonal in nature are nevertheless considered regular employees when they are repeatedly hired year after year and perform work necessary and desirable to the employer's usual business; to be classified as merely seasonal (and excluded from regular status), the employment must be limited to the duration of one season only. Furthermore, the doctrine of stare decisis applies only when the material facts of the cases are substantially the same.

The case arose from a labor dispute at Hacienda Bino, a 236-hectare sugar plantation in Kabankalan City, Negros Occidental. The conflict centered on the employment status of workers who supported the Comprehensive Agrarian Reform Program (CARP), which the landowner opposed. During the off-milling season, the employer issued a notice effectively terminating workers who favored CARP, claiming they had voluntarily resigned and that the seasonal nature of sugar farming justified the termination.

• Hacienda Bino is a 236-hectare sugar plantation located in Barangay Orong, Kabankalan City, Negros Occidental, owned and operated by Hortencia L. Starke.
• The 76 respondents were part of a 220-worker workforce performing various agricultural tasks including cultivation, planting of cane points, fertilization, watering, weeding, harvesting, and loading harvested sugarcanes.
• On July 18, 1996, during the off-milling season, petitioner Starke issued a Notice stating that workers who signed in favor of CARP were deemed to have voluntarily resigned, and only those who did not sign would be given employment.
• Respondents interpreted this as a termination of their employment and filed a complaint on September 17, 1996, alleging they were regular and permanent workers dismissed without just cause due to their support for CARP.
• Petitioner Starke contended that the notice was issued due to the seasonal nature of work and lack of available tasks during the off-season, and that respondents were seasonal employees who refused to report back when work resumed in October 1996.
• Payroll records submitted by petitioners showed that respondents had been continuously employed since 1991, availing of their services year-round rather than for single milling seasons only.
• There was no evidence presented that respondents performed work for other neighboring haciendas or that they were free to offer their services elsewhere during off-seasons.

• The ruling in Mercado, Sr. v. NLRC established that sugar workers are seasonal employees, and the Court of Appeals violated the doctrine of stare decisis by refusing to apply this controlling precedent.
• Respondents are seasonal employees because the nature of sugar farming is inherently seasonal, regardless of the plantation's size or capitalization, and Republic Act No. 6982 recognizes the seasonal nature of the sugar industry.
• The requirement to indicate the date of receipt of the decision in a motion for reconsideration is merely directory, not mandatory; the CA should have considered the motion given the timely filing and substantial amount involved.
• The determination of employment status depends on the nature of the work, not the size of the land, and respondents allegedly made their services available to neighboring haciendas.

• Mercado v. NLRC is factually distinguishable because it involved a small 17.5-hectare farm where workers labored for definite periods and freely offered services to other farm owners, whereas the 236-hectare Hacienda Bino requires continuous, year-round operations.
• Respondents have been employed continuously since 1991 and do not work for other haciendas; the vastness of the land requires their constant presence, unlike the "on-and-off" employment in Mercado.
• The requirement to state the date of receipt in a motion for reconsideration is mandatory and jurisdictional; failure to comply warrants outright denial.
• The July 18, 1996 notice constituted illegal dismissal because respondents are regular employees entitled to security of tenure.

• Procedural Issues:
  • Whether the Court of Appeals committed grave abuse of discretion in denying the motion for reconsideration for failure to indicate the date of receipt of the decision.
• Substantive Issues:
  • Whether the respondents are regular or seasonal employees.
  • Whether the doctrine of stare decisis compels the application of Mercado v. NLRC to classify respondents as seasonal employees.

• Procedural:
  • The issue is moot. Petitioner was able to raise the arguments raised in the motion for reconsideration in the instant petition for review, and assuming the CA erred in denying the motion, the petitioner was not left without any other recourse.
• Substantive:
  • The respondents are regular employees, not seasonal. The doctrine of stare decisis does not apply because the facts in Mercado (small land area of 17.5 hectares, workers free to contract with other farms) are essentially different from this case (236-hectare plantation, continuous employment since 1991, no evidence respondents worked elsewhere).
  • The primary standard for determining regular employment is the reasonable connection between the employee's activity and the usual trade or business of the employer. To be excluded from regular employment, it is not enough that the work is seasonal; the employee must have been hired only for the duration of one season. The payrolls showing employment since 1991 disprove this.
  • The employer bears the burden of proving the lawfulness of dismissal, which petitioner failed to discharge. The July 18, 1996 notice effectively terminated respondents without just or authorized cause, constituting illegal dismissal warranting reinstatement and backwages.

• Stare Decisis — Courts adhere to principles laid down in previous decisions only when applied to future cases where the facts are substantially the same; where facts are essentially different, the doctrine does not apply as a sound principle applied to one set of facts might be inappropriate when factual variances are introduced.
• Regular vs. Seasonal Employment — The primary standard for regular employment is the reasonable connection between the particular activity performed by the employee in relation to the usual trade or business of the employer. Seasonal workers who are repeatedly hired year after year become regular employees; to be considered merely seasonal, the employment must be limited to the duration of one season only.
• Burden of Proof in Illegal Dismissal Cases — The employer bears the burden of proving that the dismissal of an employee was for a valid or authorized cause; failure to discharge this burden results in a finding of illegal dismissal.

• "Under the doctrine of stare decisis, when a court has laid down a principle of law as applicable to a certain state of facts, it will adhere to that principle and apply it to all future cases in which the facts are substantially the same. Where the facts are essentially different, however, stare decisis does not apply, for a perfectly sound principle as applied to one set of facts might be entirely inappropriate when a factual variance is introduced."
• "For respondents to be excluded from those classified as regular employees, it is not enough that they perform work or services that are seasonal in nature. They must have been employed only for the duration of one season."
• "The primary standard for determining regular employment is the reasonable connection between the particular activity performed by the employee in relation to the usual trade or business of the employer."

• Mercado, Sr. v. NLRC — Distinguished; involved a small 17.5-hectare farm where workers were free to work for other farm owners after completing specific phases, unlike the 236-hectare hacienda here where workers were continuously employed and not shown to work elsewhere.
• Bacolod-Murcia Milling Co. Inc. v. NLRC — Cited by the CA; held that sugar workers may be considered in regular employment even during years when they are merely seasonal where the issues concern the determination of an employer-employee relationship and security of tenure.
• Abasolo v. NLRC and Philippine Tobacco Flue-Curing & Redrying Corporation v. NLRC — Cited to explain the factual distinctions in Mercado, noting that workers therein performed different phases of agricultural work but were free to contract with other farm owners.
• Hacienda Fatima v. National Federation of Sugarcane Workers-Food and General Trade — Cited to reiterate that Mercado involved workers hired "on and off" for single phases of work, not continuously.
• Tan v. Lagrama — Cited for the standard of regular employment and the rule that the employer bears the burden of proving the lawfulness of dismissal.

• Republic Act No. 6982 — An Act Strengthening the Social Amelioration Program in the Sugar Industry; invoked by petitioner to assert the seasonal nature of sugar work, but held insufficient to overcome evidence of regular employment where workers were hired continuously since 1991.