Equiparación de la indemnización de los temporales con los fijos.

Reciente Sentencia del Tribunal Superior de Justicia del País Vasco que equipara las indemnizaciones de los temporales con los fijos. 

Corresponde una indemnización de 20 días por año de servicio a una trabajadora con contrato temporal incardinado en un proyecto de investigación que finaliza y que a su vez se desarrollaba en un organismo adscrito a una Administración autonómica. 

Una trabajadora, cuyo contrato está ligado a un proyecto de investigación, presta sus servicios para la Fundación Vasca de Investigación e Innovación Sanitarias. Su contrato se ve extinguido por la finalización del proyecto al que estaba adscrito y la extinción es conforme a derecho, no siendo aplicables los límites temporales de los contratos por obra o servicio y las consecuencias de su incumplimiento, al establecerlo así la regulación específica de los contratos para la realización de proyectos específicos de investigación científica y técnica.

La Fundación demandada indemnizó en el momento de la extinción con lo que correspondía al contrato temporal suscrito, pero el TSJ interpreta este derecho a la indemnización  teniendo en cuenta la reciente sentencia del TJUE 14-9-16, C-596/14 y estas son sus conclusiones:

  1. Ha de seguirse la interpretación de la sentencia del TJUE antes mencionada por la primacía de la jurisprudencia comunitaria, así como por la prevalencia del derecho de la UE frente al interno. Ha de considerarse, no obstante, que dicha sentencia no crea un derecho indemnizatorio ex novo, sino que recuerda la interpretación auténtica que hay que dar al Acuerdo Marco sobre el trabajo de duración determinada (Dir 1999/70/CE Anexo).
  2. La empleadora es un organismo que se incardina dentro de la Administración Autonómica y, por lo tanto, puede invocarse directamente la aplicación de la Directiva (eficacia vertical del Acuerdo Marco), lo que no sería posible de tratarse de un empleador privado.
  3. El contrato firmado por la trabajadora es un contrato de duración determinada, por lo que le es aplicable la doctrina establecida por el TJUE, aunque no estemos ante un contrato de interinidad. En ambos casos, el contemplado en la sentencia de TJUE y este que estamos analizando, el punto de partida es idéntico: suscripción de un contrato de duración incierta y la terminación por decisión de la empleadora basada en que ya no existe causa suficiente para su mantenimiento.
  4. Tanto en el supuesto de una trabajadora fija de plantilla como en el del que suscribe un contrato de duración determinada, cuando la empresa decide extinguir unilateralmente la relación laboral por concurrir una causa legalmente justificada, por motivos ajenos a la voluntad de la trabajadora, se produce una identidad en la objetivación de la causa. De este modo, la terminación del contrato de investigación puede considerarse una causa productiva (ET art.51.1 y 52.c).
  5. Aunque el contrato temporal analizado sí tiene reconocida legalmente una indemnización en el momento de extinguirse (12 días por año de servicio), la resolución europea explica que el problema de distinción indemnizatoria no se da entre temporales, sino entre los contratos de duración determinada frente a los fijos. En este caso, las circunstancias en las que la trabajadora presta sus servicios la hacen perfectamente comparable con la de un trabajador fijo de la Fundación. Por lo tanto, no hay una justificación objetiva y razonable para que la trabajadora no perciba la misma indemnización que le correspondería a un trabajador fijo despedido por causas productivas, es decir, 20 días por año de servicio.

 

 

 

 

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