Non-Impairment:

DE JESUS MESINA, Petitioner

vs. CA and CETUS, Respondent
GR No. 100228, July 13, 1994
Ponente: BELOSILLO, J.
Nature of Case:
Parcel of land subject of a verbal lease as far back as the late 1800s in
which the lessee refuse to give us the property while subleasing the
same without the consent of the lessor.
FACTS:
A property in Quiapo, Manila is owned by Gregorio Araneta from whom
Clemente de Jesus, petitioners predecessor-in-interest, leased it way
back in the late 1800s. In 1921, Clemente bought 2 houses erected on
the lot. He died in 1972 and survived by petitioners, his daughter Paz
Mesina and his grandson Peter de Jesus. Both of whom lived in the
property since birth. Paz has transferred residence in Pasay City since
then while Peter stayed in one of the house and sub-leased the other
house to different tenants who are paying rentals to petitioners.
The owner sold the land to Susana Realty which in turn sold the same to
Cetus Corporation in 1984. Cetus filed a complaint for ejectment against
Paz Mesina on the ground that the property was assigned by the original
lessor who in turn sublet the premises to other persons without the
written consent of the lessor.
The Trial Court dismissed the complaint on the ground that Paz Mesina
did not occupy the lot as an assignee but by operation of law as the
successor in interest. The court also ruled that the leasehold right in the
case was acquired prior to the effectivity of BP 877 which has no
retroactive application. BP 877 prohibits the assignment of lease or
subleasing of the property to third parties.
Sometime in 1989, Cetus again initiated ejectment proceedings, this
time against both Paz Mesina and Peter de Jesus to vacate the leased
premises. Trial Court rendered judgment and ordered Paz Mesima and de
Jesus to vacate the property; however RTC reversed the judgment and
ordered dismissal of the complaint. On May 1991, the CA reversed the
decision of the RTC and reinstated the decision of the Trial Court, hence
this petition was filed to Supreme Court as petitioners invoked res
judicata.

ISSUE:
Whether the application of BP 877 violates the impairment clause.
ACTION OF THE COURT:
The Court looked into the identity of parties and of cause of action
between the first case and the instant proceedings.
COURT RATIONALE ON THE ABOVE FACTS:
No. the Court in asserting the identity of the parties between the two
actions positively affirmed that there were similarities of the identities
between the two proceedings but as to identity of the causes of action,
there is none. The first case was based on the demand letter to vacate
the premises dated in 1985 for subleasing the premises which was an
express violation of BP 877. The present case is based on the demand
letter dated in 1989 for subleasing the premises after November 18,
1985 and before Jul 12, 1989. While the first action has already attained
finality, it merely refers to the principal lease contract and to the act of
subleasing the property prior to November 18, 1985.
The existing contract between petitioners and respondent Cetus is
admittedly, a verbal month to month lease contract which expires at the
end of every thirty day period but which automatically renewed for the
next thirty day period, repeating the same cycle until the implied lease
is expressly terminated. Each 30 day lease contract is separate and
distinct from the other 30 day period, thus there can be no identity in
the causes of action between the two cases.
The Court ruled that when the contract of lease was impliedly renewed
after the effectivity of BP 877, that renewed lease became the subject to
the provisions of the statute and any act of subleasing the premises
without the consent of the lessor would be invalid under its provisions.
Hence, the impairment clause is no longer inviolate.
SUPREME COURT RULING:

WHEREFORE, the instant petition for review on certiorari is DISMISSED

for lack of merit.

(Non-Impairment Clause)
MANILA JOCKEY CLUB, INC. vs COURT OF APPEALS
MANIAL JOCKEY CLUB, INC. and PHILIIPINE RACING CLUB,
Petitioners,
- versus THE COURT OF APPEALS and PHILIPPINE RACING COMMISSION,
Respondents.
G.R. No. 103533
December 15, 1998
Ponente: QUISUMBING, J.
Davide, Jr., C.J., Melo, Vitug, and Panganiban, JJ., concur
BRIEF:
This is a petition for review on certiorari seeking the reversal of the
decision of the Court of Appeals in CA-G.R. SP No. 25251 dated
September 17, 1991 and the resolution dated January 8, 1992, which
denied the motion for reconsideration. At issue here is the control and
disposition of breakages in connection with the conduct of horse-racing.
FACTS:
On October 23, 1992, petitioners MJCI and PRCI, were granted franchises
to operate and maintain race tracks for horse racing by virtue of RA Nos.
6631 and 6632, and allowed to hold races on the following dates:
Xxx Saturdays, Sundays and official holidays of the year, excluding
Thursdays and Fridays of the Holy Week, Independence Day, Election
day, and Rizal day.xxx (Sec 7 of R.A. 6631)
Said laws carried provisions on the allocations of breakages to
beneficiaries as follows:

Provincial/City hospitals 25%

Rehabilitation of drug addicts 25%
Amateur Athletes Foundation 25%
Charitable Institutions 25%
On March 20, 1974, PD No. 420 was issued creating the Philippine
Racing Commission (PHILRACOM), giving it exclusive jurisdiction and
control over every aspect of the conduct of horse racing. By virtue of
this power, the PHILRACOM authorized the holding of races on
Wednesdays, Thursdays, and Tuesdays in addition to those days
mentioned in RA 6631 and 6632. In connection with the new schedule of
races, the PHILRACOM declared that the breakages belonged to the
racing clubs concerned.
On December 16, 1986 President Corazon Aquino amended certain
provisions of RA 6631 and 6632 through EO Nos. 88 and 89. Under these
Executive Orders, the breakages were allocated as follows:
Provincial/City hospitals 25%
Rehabilitation of drug addicts 25%
Racing Commission 25%
Charitable Institutions 25%
Thereafter, herein respondent PHILRACOM sent a series of demand
letters to petitioners MJCI and PRCI, requesting its share in the
breakages of mid-week races (Tuesdays, Wednesdays, and Thursday
races) as effected by EO Nos. 88 and 89. Petitioners ignored said
demand and instead filed a petition for declaratory relief before the
Regional Trial Court of Makati.
ISSUE:
Whether the petitioners cannot be held retroactively liable to
PHILRACOM for breakages prior to the effectivity of E.O. No. 88 and 89
ACTIONS OF THE COURT
RTC: The ownership by MJCI and PRCI of the breakages derived from
mid-week races shall not be disturbed.
CA: Reversed the RTC decision. Ordered MJCI and PRCI to remit to
PHILRACOM its share under EO 88 an 89 derived from mid-week races.
SC: Affirmed the decision of the CA.

COURT RATIONALE ON THE ABOVE FACTS:

The holding of horse races on Wednesdays is in addition to the existing
schedule of races authorized by law. Since this new schedule became
part of R.A. 6631 and 6632 the set of procedures in the franchise laws
applicable to the conduct of horse racing business must likewise be
applicable to Wednesday or other mid-week races. Petitioners should
therefore remit the proceeds of breakages to those benefactors
designated by the aforesaid laws.
The petitioners contend that they cannot be held retroactively liable to
respondent PHILRACOM for breakages prior to the effectivity of E.O. Nos.
88 and 89. They assert that the real intent behind E.O. Nos. 88 and 89
was to favor the respondent PHILRACOM anew with the benefits which
formerly had accrued in favor of Philippine Amateur Athletic Federation
(PAAF). They opine that since laws operate prospectively unless the
legislator intends to give them retroactive effect, the accrual of these
breakages should start on December 16, 1986, the date of effectivity of
E.O. Nos. 88 and 89.
The petitioners should have properly set aside the amount for the
defunct PAAF, until an alternative beneficiary was designated, which as
subsequently provided for by Executive Order Nos. 88 and 89, is
PHILRACOM.

Nor could we be oblivious to the reality that horse racing although

authorized by law is still a form of gambling. Gambling is essentially
antagonistic to the aims of enhancing national productivity and selfreliance. For this reason, legislative franchises impose limitations on
horse racing and betting. Petitioners contention that a gambling
franchise is a public contract protected by the Constitutional provision
on non-impairment of contract could not be left unqualified. For as well
said in Lim vs. Pacquing:
x x x it should be remembered that a franchise is not in the strict sense
a simple contract but rather it is, more importantly, a mere privilege
specially in matters which are within the governments power to regulate
and even prohibit through the exercise of the police power. Thus, a
gambling franchise is always subject to the exercise of police power for
the public welfare. X x x

That is why we need to stress anew that a statute which authorizes a

gambling activity or business should be strictly construed, and every
reasonable doubt be resolved so as to limit rather than expand the
powers and rights claimed by franchise holders under its authority.

SUPREME COURT RULING:

WHEREFORE, there being no reversible error, the appealed decision
and the resolution of the respondent Court of Appeals in CA-G.R. SP No.
25251, are hereby AFFIRMED, and the instant petition is hereby
DENIED for lack of merit.

Respondent and FASAP entered into a Collective Bargaining Agreement (CBA)

incorporating the terms and conditions of their agreement. Petitioners and several
female cabin crews manifested that the aforementioned CBA provision on
compulsory retirement is discriminatory, and demanded for an equal treatment with
their male counterparts. This demand was reiterated in a letter by petitioners'
counsel addressed to respondent demanding the removal of gender discrimination
provisions in the coming re-negotiations of the PAL-FASAP CBA.
Petitioners assail Section 144 of the CBA entered into by PAL-FASAP and
FASAP, which states as follows:
A. For the Cabin Attendants hired before 22 November 1996:
xxx
3. Compulsory Retirement
Subject to the grooming standards provisions of this Agreement,
compulsory retirement shall be fifty-five (55) for females and
sixty (60) for males. x x x.

Non-impairment
G.R. No. 172013

October 2, 2009

PATRICIA HALAGUEA, MA. ANGELITA L. PULIDO, MA. TERESITA P.

SANTIAGO, MARIANNE V. KATINDIG, BERNADETTE A. CABALQUINTO,
LORNA B. TUGAS, MARY CHRISTINE A. VILLARETE, CYNTHIA A.
STEHMEIER, ROSE ANNA G. VICTA, NOEMI R. CRESENCIO, and other flight
attendants of PHILIPPINE AIRLINES, Petitioners,
vs.
PHILIPPINE AIRLINES INCORPORATED, Respondent.
Nature of Case
This is a petition for review on certiorari under Rule 45 of the Rules of
Court seeking to annul and set aside the Decision and the Resolution of
the Court of Appeals (CA) in CA-G.R. SP. No. 86813.
Brief
Jurisdiction of the court is determined on the basis of the material
allegations of the complaint and the character of the relief prayed for
irrespective of whether plaintiff is entitled to such relief.
FACTS
Petitioners are female flight attendants of respondent Philippine Airlines (PAL) and
are members of the Flight Attendants and Stewards Association of the Philippines
(FASAP), a labor organization certified as the sole and exclusive certified as the
sole and exclusive bargaining representative of the flight attendants, flight
stewards and pursers of respondent.

Petitioners filed a Special Civil Action for Declaratory Relief with Prayer
for the Issuance of Temporary Restraining Order and Writ of Preliminary
Injunction with the Regional Trial Court (RTC) against respondent for the
invalidity of Section 144, Part A of the PAL-FASAP CBA. The RTC granted
the petition. Aggrieved, respondent filed a Petition for Certiorari and
Prohibition with Prayer for a Temporary Restraining Order and Writ of
Preliminary Injunction with the Court of Appeals (CA) praying that the
order of the RTC, which denied its objection to its jurisdiction, be annuled
and set aside for having been issued without and/or with grave abuse of
discretion amounting to lack of jurisdiction. The CA granted the
respondents petition.
ISSUE/S of the CASE
Whether or not RTC has jurisdiction over the petitioners' action
challenging the legality or constitutionality of the provisions on the
compulsory retirement age contained in the CBA between respondent
PAL and FASAP
HELD
Yes. The question whether Section 114, Part A of the PAL-FASAP CBA is
discriminatory or not is a question of fact. This would require the
presentation and reception of evidence by the parties in order for the
trial court to ascertain the facts of the case and whether said provision
violates the Constitution, statutes and treaties. A full-blown trial is
necessary, which jurisdiction to hear the same is properly lodged with
the the RTC. Therefore, a remand of this case to the RTC for the proper

determination of the merits of the petition for declaratory relief is just

and proper.
The subject of litigation is incapable of pecuniary estimation, exclusively
cognizable by the RTC, pursuant to Section 19 (1) of Batas Pambansa
Blg. 129, as amended. Being an ordinary civil action, the same is beyond
the jurisdiction of labor tribunals.
The said issue cannot be resolved solely by applying the Labor Code.
Rather, it requires the application of the Constitution, labor statutes, law
on contracts and the Convention on the Elimination of All Forms of
Discrimination Against Women (CEDAW), and the power to apply and
interpret the constitution and CEDAW is within the jurisdiction of trial
courts, a court of general jurisdiction. The jurisdiction of labor arbiters
and the NLRC under Article 217 of the Labor Code is limited to disputes
arising from an employer-employee relationship which can only be
resolved by reference to the Labor Code, other labor statutes, or their
collective bargaining agreement. Not every controversy or money claim
by an employee against the employer or vice-versa is within the
exclusive jurisdiction of the labor arbiter. Actions between employees
and employer where the employer-employee relationship is merely
incidental and the cause of action precedes from a different source of
obligation is within the exclusive jurisdiction of the regular court.18
Here, the employer-employee relationship between the parties is merely
incidental and the cause of action ultimately arose from different
sources of obligation, i.e., the Constitution and CEDAW.
Thus, where the principal relief sought is to be resolved not by reference
to the Labor Code or other labor relations statute or a collective
bargaining agreement but by the general civil law, the jurisdiction over
the dispute belongs to the regular courts of justice and not to the labor
arbiter and the NLRC. In such situations, resolution of the dispute
requires expertise, not in labor management relations nor in wage
structures and other terms and conditions of employment, but rather in
the application of the general civil law. Clearly, such claims fall outside
the area of competence or expertise ordinarily ascribed to labor arbiters
and the NLRC and the rationale for granting jurisdiction over such claims
to these agencies disappears.
SUPREME COURT RULING:
WHEREFORE, the petition is PARTLY GRANTED. The Decision and Resolution of
the Court of Appeals, dated August 31, 2005 and March 7, 2006, respectively, in
CA-G.R. SP. No. 86813 are REVERSED and SET ASIDE. The Regional Trial

Court of Makati City, Branch 147 is DIRECTED to continue the proceedings in Civil
Case No. 04-886 with deliberate dispatch.

This is a Petition for Review on Certiorari under Rule 45 of the Rules of

Court seeking to set aside the Decision1 and the Resolution2 of the Court
of Appeals (CA) in CA-G.R. SP. No. 87069, which annulled and set aside
the Decision and Order of the Voluntary Arbitrator dated July 12, 2004
and August 11, 2004, respectively.
FACTS
Petitioner PNCC Skyway Corporation Traffic Management and Security
Division Workers' Organization (PSTMSDWO) is a labor union duly
registered with the DOLE. Respondent PNCC Skyway Corporation is a
corporation duly organized and operating under and by virtue of the
laws of the Philippines.
On November 15, 2002, petitioner and respondent entered into a
Collective Bargaining Agreement (CBA) incorporating the terms and
conditions of their agreement which included vacation leave and
expenses for security license provisions.
Article VIII, Section 1 (b) of the CBA, the pertinent provisions of the CBA
relative to vacation leave and sick leave that the company shall
schedule the vacation leave of employees during the year taking into
consideration the request of preference of the employees. Any unused
vacation leave shall be converted to cash and shall be paid to the
employees on the first week of December each year."
Non-Impairment Clause
PNCC SKYWAY TRAFFIC MANAGEMENT AND SECURITY DIVISION
WORKERS ORGANIZATION (PSTMSDWO), represented by its President,
RENE SORIANO, Petitioner,
vs.
PNCC SKYWAY CORPORATION, Respondent.
G.R. No. 171231
February 17, 2010
Ponente: PERALTA, J.:
Nature of Case:
This is a Petition for Review on Certiorari.
BRIEF

Petitioner objected to the implementation of the said memorandum. It

insisted that the individual members of the union have the right to
schedule their vacation leave. It opined that the unilateral scheduling of
the employees' vacation leave was done to avoid the monetization of
their vacation leave in December 2004.
Petitioner also demanded that the expenses for the required in-service
training of its member security guards, as a requirement for the renewal
of their license, be shouldered by the respondent. However, the
respondent did not accede to petitioner's demands and stood firm on its
decision to schedule all the vacation leave of petitioner's members.
Due to the disagreement between the parties, petitioner elevated the
matter to the DOLE-NCMB for preventive mediation. For failure to settle
the issue amicably, the parties agreed to submit the issue before the
voluntary arbitrator.
Respondent filed a motion for reconsideration, which the voluntary

arbitrator denied. Aggrieved, respondent filed a Petition for Certiorari

with Prayer for Temporary Restraining Order and/or Writ of Preliminary
Injunction with the CA, and the CA annulled and setting aside the
decision and order of the voluntary arbitrator. The CA ruled that since
the provisions of the CBA were clear, the voluntary arbitrator has no
authority to interpret the same beyond what was expressly written.
Petitioner filed a motion for reconsideration, which the CA denied.
Hence, the instant petition assigning the following errors:
ISSUE/S of the CASE
Whether the Court of Appeals erred in holding that the management has
sole discretion to schedule the vacation leave of the petitioner
COURT RATIONALE ON THE ABOVE FACTS
The rule is that where the language of a contract is plain and
unambiguous, its meaning should be determined without reference to
extrinsic facts or aids. The intention of the parties must be gathered
from that language, and from that language alone. Stated differently,
where the language of a written contract is clear and unambiguous, the
contract must be taken to mean that which, on its face, it purports to
mean, unless some good reason can be assigned to show that the words
used should be understood in a different sense.
In the case at bar, the contested provision of the CBA is clear and
unequivocal. Article VIII, Section 1 (b) of the CBA categorically provides
that the scheduling of vacation leave shall be under the option of the
employer. The preference requested by the employees is not controlling
because respondent retains its power and prerogative to consider or to
ignore said request.
Thus, if the terms of a CBA are clear and leave no doubt upon the
intention of the contracting parties, the literal meaning of its stipulation
shall prevail. RFM Corporation-Flour Division and SFI Feeds Division v.
Kasapian ng Manggagawang Pinagkaisa-RFM (KAMPI-NAFLU-KMU) and
Sandigan at Ugnayan ng Manggagawang Pinagkaisa-SFI (SUMAPI-NAFLUKMU)G.R. No. 162324, February 4, 2009.In fine, the CBA must be strictly
adhered to and respected if its ends have to be achieved, being the law
between the parties. The parties cannot be allowed to change the terms
they agreed upon on the ground that the same are not favorable to
them.
There is, thus, no basis for the Voluntary Arbitrator to interpret the

subject provision relating to the schedule of vacation leaves as being

subject to the discretion of the union members. There is simply nothing
in the CBA which grants the union members this right.
It must be noted the grant to management of the right to schedule
vacation leaves is not without good reason. Indeed, if union members
were given the unilateral discretion to schedule their vacation leaves,
the same may result in significantly crippling the number of key
employees of the petitioner manning the toll ways on holidays and other
peak seasons, where union members may wittingly or unwittingly
choose to have a vacation. Put another way, the grant to management
of the right to schedule vacation leaves ensures that there would always
be enough people manning and servicing the toll ways, which in turn
assures the public plying the same orderly and efficient toll way service.
Indeed, the multitude or scarcity of personnel manning the tollways
should not rest upon the option of the employees, as the public using
the skyway system should be assured of its safety, security and
convenience.
Although the preferred vacation leave schedule of petitioner's members
should be given priority, they cannot demand, as a matter of right that
their request be automatically granted by the respondent. If the
petitioners were given the exclusive right to schedule their vacation
leave then said right should have been incorporated in the CBA. In the
absence of such right and in view of the mandatory provision in the CBA
giving respondent the right to schedule the vacation leave of its
employees, compliance therewith is mandated by law.
In the grant of vacation leave privileges to an employee, the employer is
given the leeway to impose conditions on the entitlement to and
commutation of the same, as the grant of vacation leave is not a
standard of law, but a prerogative of management. Sobrepe, Jr. v. Court
of Appeals, 345 Phil. 714. It is a mere concession or act of grace of the
employer and not a matter of right on the part of the employee. Thus, it
is well within the power and authority of an employer to impose certain
conditions, as it deems fit, on the grant of vacation leaves, such as
having the option to schedule the same.
Petitioner's contention that labor contracts should be construed in favor
of the laborer is without basis and, therefore, inapplicable to the present
case. This rule of construction does not benefit petitioners because, as
stated, there is here no room for interpretation. Since the CBA is clear
and unambiguous, its terms should be implemented as they are written.

This brings us to the issue of who is accountable for the in-service

training of the security guards. On this point, we find the petition
meritorious.
Although it is a rule that a contract freely entered into between the
parties should be respected, since a contract is the law between the
parties, there are, however, certain exceptions to the rule, specifically
Article 1306 of the Civil Code, which provides:
The contracting parties may establish such stipulations, clauses, terms
and conditions as they may deem convenient, provided they are not
contrary to law, morals, good customs, public order, or public policy.
Moreover, the relations between capital and labor are not merely
contractual. "They are so impressed with public interest that labor
contracts must yield to the common good x x x." The supremacy of the
law over contracts is explained by the fact that labor contracts are not
ordinary contracts; they are imbued with public interest and therefore
are subject to the police power of the state. However, it should not be
taken to mean that provisions agreed upon in the CBA are absolutely
beyond the ambit of judicial review and nullification. If the provisions in
the CBA run contrary to law, public morals, or public policy, such
provisions may very well be voided.

Non-impairment Clause
LEYTE GEOTHERMAL POWER PROGRESSIVE EMPLOYEES UNION ALU TUCP (Union for brevity)
Vs
PHILIPPINE NATIONAL OIL COMPANY - ENERGY DEVELOPMENT
CORPORATION (PNOC-EDC)
GR No. 170351 , March 30, 2011
NACHURA, J.
Nature: Certiorari appeal for the decision of the CA
Facts:

Respondent is a GOCC engaged in exploration, development,

utilization, generation and distribution of energy resources like
geothermal energy. One of its project is the Leyte Geothermal
Power Project located at the Greater Tongonan Geothermal
Reservation in Leyte. Said project is composed of the Tongonan 1
Geothermal Project (T1GP) and the Leyte Geothermal Production
Field Project (LGPF) which provide the power and electricity
needed not only in the provinces and cities of Central and
Eastern Visayas (Region VII and VIII), but also in the island of
Luzon as well. composed of the Tongonan 1 Geothermal Project
(T1GP) and the Leyte Geothermal Production Field Project (LGPF)
which provide the power and electricity needed not only in the
provinces and cities of Central and Eastern Visayas (Region VII
and VIII), but also in the island of Luzon as well.

Petitioner is a legitimate labor organization, duly registered with

the Department of Labor and Employment (DOLE) Regional Office
No. VIII, Tacloban City

Sometime in 1998 when the project was about to be completed,

the [respondent] proceeded to serve Notices of Termination of
Employment upon the employees who are members of the
petitioner.

On December 28, 1998, the petitioner filed a Notice of Strike with

DOLE on the ground of purported commission of unfair labor

SUPREME COURT RULING:

WHEREFORE, the petition is PARTIALLY GRANTED. The Decision and
Resolution of the Court of Appeals, dated October 4, 2005 and January
23, 2006, respectively, in CA-G.R. SP. No. 87069 is MODIFIED. The cost
of in-service training of the respondent company's security guards shall
be at the expense of the respondent company. This case is remanded to
the voluntary arbitrator for the computation of the expenses incurred by
the security guards for their in-service training, and respondent
company is directed to reimburse its security guards for the expenses
incurred.

practice for "refusal to bargain collectively, union busting and

mass termination." On the same day, the petitioner declared a
strike and staged such strike.

Secretary of Labor Bienvenido E. Laguesma intervened and

issued the Order, dated January 4, 1999, certifying the labor
dispute to the NLRC for compulsory arbitration. Accordingly, all
the striking workers were directed to return to work within twelve
(12) hours from receipt of the Order and for the [respondent] to
accept them back under the same terms and conditions of
employment prior to the strike. Further, the parties were directed
to cease and desist from committing any act that would
exacerbate the situation.
In effect, the petitioner did not abide by [the] assumption order
issued by the Secretary of Labor.
Consequently, on January 15, 1999, the [respondent] filed a
Complaint for Strike Illegality, Declaration of Loss of Employment
and Damages at the NLRC-RAB VIII in Tacloban City and at the
same time, filed a Petition for Cancellation of Petitioners
Certificate of Registration with DOLE, Regional Office No. VIII.

Issue:
1. WON there is a violation of non-impairment clause?

Actions of the Court

NLRC 4th Division: Granted the complaint.
MR was denied.
CA:
Dismissed the petition for certiorari
Held:
No. The supremacy of the law over the nomenclature of the contract and
the stipulations contained therein is to bring to life the policy enshrined
in the Constitution to "afford full protection to labor." Thus, labor
contracts are placed on a higher plane than ordinary contracts; these
are imbued with public interest and therefore subject to the police power
of the State. Thus, project employment contracts which fix the
employment for a specific project or undertaking remain valid under the
law:
The records reveal that the officers and the members of petitioner Union
signed employment contracts indicating the specific project or phase of
work for which they were hired, with a fixed period of employment. It
also shows that petitioners voluntarily signed the employment contract.
Clearly, therefore, petitioners being project employees, or, to use the
correct term, seasonal employees, their employment legally ends upon
completion of the project or the [end of the] season. The termination of
their employment cannot and should not constitute an illegal dismissal.