Short answer. Yes, for liability. Article 109 of the Labor Code says the client company and your contractor or subcontractor are considered as direct employers when working out civil liability for Labor Code violations. Calling the arrangement a "contractor setup" on paper does not change who can be made to answer for what you are owed.
What the law says
For purposes of determining the extent of their civil liability under this Chapter, they shall be considered as direct employers.
Labor Code, Article 109 — Solidary Liability. Read the full provision →
What Article 109 actually deems
Article 109 provides that the employer or indirect employer shall be held responsible with his contractor or subcontractor for any violation of any provision of this Code, and that, for purposes of determining the extent of their civil liability under this Chapter, both shall be considered as direct employers. The deeming clause is narrow in scope — it fixes civil liability — but broad in effect: it applies regardless of how the contract between the company and your agency is worded.
"Contractor setup" labels do not control
A contract that calls the arrangement job contracting, or that disclaims any employer relationship between you and the client company, does not defeat Article 109. The provision opens with "the provisions of existing laws to the contrary notwithstanding," signaling that it overrides private arrangements that would otherwise shield the client from responsibility. What the parties call the setup on paper is not what decides whether the client answers for a Labor Code violation.
This is about liability, not your employment status
Being treated as a direct employer for civil liability under this Chapter is not the same as being declared your regular employer for all purposes, such as security of tenure or benefits tied to length of service with the client. Those questions turn on separate rules about who actually controls and directs your work. Article 109 answers a narrower question: who can be made to pay when the Code is violated.
The deeming clause is also expressly about civil liability. It settles who can be made to pay; it does not transfer to the client whatever other consequences the Code attaches to an employer, and it does not release the contractor, which remains bound alongside. Where the client ends up paying, sorting out reimbursement between the two of them is their affair and is not something the worker has to wait for.
What to do if you are pursuing a claim
Because the client company is treated as a direct employer for liability, you do not need to establish a full employer-employee relationship with it before holding it responsible under Article 109 — you need to show the violation occurred while you worked under that contracting arrangement. Gather the contract, deployment papers, and records connecting your work to the client, and bring them to a lawyer to work out how the claim should be framed.
The idea of an indirect employer comes from Articles 106 and 107, which cover the person who contracts out work or engages an independent contractor to perform a job for him. Article 109 then attaches responsibility to that status. So the documents that matter are the ones showing the client engaged your agency to supply the work you were doing — the service agreement, deployment orders, gate passes, schedules and any instruction that came from the client's own staff.