ABELLA v. NLRC

G.R. No. 71813 July 20, 1987, PARAS, J.

(Labor Standards: Proper Construction and Interpretation of labor Laws)

FACTS

PETITIONER Abella leased a farmland from Ramona for a period of 10 years and renewable for another 10 years at the option of the former. Abella hired the private respondents Quitco and Dionele. Abella renewed the lease for another ten years. At the expiration of the lease, she dismissed both private respondents and turned over the hacienda to the owners. Private respondents filed a complaint against petitioner. for overtime pay, reinstatement, and illegal dismissal. The Labor Arbiter ruled that the dismissal was warranted  by the cessation of business, but the respondents are entitled to separation pay, invoking Art. 284 of the Labor Code, as amended.

ISSUE
Whether or not private respondents are entitled to separation pay.

RULING

The Court upheld the ruling of the Labor Arbiter that  Article 284 is the applicable law in this case. Art 284, as amended refers to employment benefits to farm hands who were not parties to petitioner's lease contract with the owner of Hacienda Danao-Ramona. That contract cannot have the effect of annulling subsequent legislation designed to protect the interest of the working class.
It is well-settled that in the implementation and interpretation of the provisions of the Labor Code and its implementing regulations, the workingman's welfare should be the primordial and paramount consideration. It is the kind of interpretation which gives meaning and substance to the liberal and compassionate spirit of the law as provided for in Article 4 of the New Labor Code which states that "all doubts in the implementation and interpretation of the provisions of this Code including its implementing rules and regulations shall be resolved in favor of labor." The policy is to extend the applicability of the decree to a greater number of employees who can avail of the benefits under the law, which is in consonance with the avowed policy of the State to give maximum aid and protection to labor.