Short answer. Not under this article's own definition. Article 106 of the Labor Code defines labor-only contracting as requiring, among other things, that the workers supplied are performing activities directly related to the principal business of the employer they are placed with. Placing workers to do jobs unrelated to the client's main business does not fit that definition as written.
What the law says
There is "labor-only" contracting where the person supplying workers to an employer does not have substantial capital or investment in the form of tools, equipment, machineries, work premises, among others, and the workers recruited and placed by such person are performing activities which are directly related to the principal business of such employer.
Labor Code, Article 106 — Contractor Or Subcontractor. Read the full provision →
Two conditions have to be met together
Article 106 defines labor-only contracting as existing where the person supplying workers to an employer does not have substantial capital or investment in the form of tools, equipment, machineries, work premises, among others, and the workers recruited and placed by such person are performing activities which are directly related to the principal business of such employer. That definition is joined by "and" — lack of substantial capital on its own is not enough; the workers also have to be doing work directly tied to the client's principal business.
Why unrelated work does not satisfy the definition
The phrase directly related to the principal business of such employer is doing real work in this definition. If the workers supplied are performing tasks that have nothing to do with what the client company is actually in business to do, that second condition is not met, regardless of how little capital the supplier has. On the article's own terms, an arrangement missing that element is not what Article 106 defines as labor-only contracting.
What the article does not tell you instead
Article 106 tells you what labor-only contracting is; it does not itself say what an arrangement involving unrelated work should be called instead, or what rules would govern it. The Secretary of Labor and Employment is given authority under this same article to make appropriate distinctions between labor-only contracting and job contracting through regulations, so the article anticipates that finer line-drawing happening elsewhere rather than settling every category itself.
Why the label matters
The consequence Article 106 attaches to labor-only contracting is significant: the person or intermediary shall be considered merely as an agent of the employer who shall be responsible to the workers in the same manner and extent as if the latter were directly employed by him. That is why whether an arrangement actually meets the article's definition — including the directly-related-work element — determines whether the client employer ends up treated as the workers' real employer under this provision.