Who are Field Personnel?

Hilario Dasco, et al. Vs. Philtranco Service Enterprises Inc.
G.R. No. 211141. June 29, 2016

Who are field personnel?

The determination of whether bus drivers and/or conductors are considered as field personnel was already threshed out in the case of Auto Bus Transport Systems, Inc. v. Bautista,as a general rule, [field personnel] are those whose performance of their job/service is not supervised by the employer or his representative, the workplace being away from the principal office and whose hours and days of work cannot be determined with reasonable certainty; hence, they are paid specific amount for rendering specific service or performing specific work. If required to be at specific laces at specific times, employees including drivers cannot be said to be field personnel despite the fact that they are performing work away from the principal office of the employee.

The definition of a “field personnel” is not merely concerned with the location where the employee regularly performs his duties but also with the fact that the employee’s performance is unsupervised by the employer.

Evidently, the petitioners are not field personnel as defined above and the NLRC’s finding in this regard is by the established facts of this case: (1) the petitioners, as bus drivers and/or conductors, are directed to transport their passengers at a specified time and place; (2) they are not given the discretion to select and contract with prospective passengers; (3) their actual work hours could be determined with reasonable certainty, as well as their average trips per month; and ( 4) the respondents supervised their time and performance of duties.