DESPITE THE ABSENCE OF ANY JUST OR AUTHORIZED CAUSE
FOR DISMISSAL.
III.......PUBLIC RESPONDENT GRAVELY ABUSED ITS DISCRETION IN
RULING THAT THE TERMINATION OF PETITIONERS WAS VALID,
DESPITE THE FACT THAT PETITIONERS WERE NOT GIVEN AN
OPPORTUNITY TO BE HEARD PRIOR TO THEIR TERMINATION.
IV.......PUBLIC RESPONDENT GRAVELY ABUSED ITS DISCRETION IN
RULING THAT PETITIONERS ARE NOT ENTITLED TO ANY
RETIREMENT BENEFIT UNDER THE OPTIONAL EARLY RETIREMENT
POLICY ANNOUNCED BY RESPONDENTS.
V.......PUBLIC RESPONDENT GRAVELY ABUSED ITS DISCRETION IN
FAILING TO RULE THAT, EVEN IN THE ABSENCE OF AN OPTIONAL
EARLY RETIREMENT POLICY ANNOUNCED BY RESPONDENTS,
PETITIONERS WERE STILL ENTITLED TO RECEIVE 100% OF THEIR
TOTAL CREDITED CONTRIBUTIONS TO THE CEIP, AS EXPRESSLY
PROVIDED IN PARS. 2 (g) AND 2 (h) OF THE LETTER MEMORANDUM
DATED MARCH 9, 1977 (ANNEX E OF ANNEX C-PETITION) AND PAR.
III, SEC. (c) AND PAR. III, SEC. (b) OF THE CEIP (ANNEX D-PETITION)
WHICH WERE ISSUED BY RESPONDENTS.
VI.......PUBLIC RESPONDENT GRAVELY ABUSED ITS DISCRETION IN
FAILING TO RULE ON THE LIABILITY FOR DAMAGES OF
RESPONDENTS FOR HAVING WRONGFULLY AND MALICIOUSLY
CAUSED THE NAME OF PETITIONER MILLARES TO BE PLACED IN
THE POEA WATCHLIST AND THEREBY PREVENTING HIS TIMELY
DEPARTURE.
VII.......PUBLIC RESPONDENT GRAVELY ABUSED ITS DISCRETION IN
FAILING TO RULE ON THE LIABILITY OF RESPONDENTS FOR
PAYMENT OF MORAL AND EXEMPLARY DAMAGES, AS WELL AS
ATTORNEYS FEES AND COSTS OF LITIGATION.14[14]
Petitioners contend that public respondent NLRC gravely abused its discretion in ruling
that they are not regular employees but are merely contractual employees whose
employments are terminated every time their contracts of employment expire.
Petitioners further aver that after rendering twenty (20) consecutive years of service,
performing activities which were necessary and desirable in the trade or business of
private respondents, they should be considered regular employees under Article 280 of
the Labor Code. Consequently, they may only be dismissed for any of the just or
authorized causes for dismissal provided by law. Furthermore, petitioners asseverate
14[14]
Id., at 30-31.