Title
Abad vs. Roselle Cinema
Case
G.R. No. 141371
Decision Date
Mar 24, 2006
Petitioners claimed illegal dismissal and unpaid benefits; SC ruled voluntary termination, awarding partial monetary claims for 1996, denying separation pay and backwages.
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Case Digest (G.R. No. 141371)

Facts:

Background of the Case

  • Petitioners Edna Abad, Joseph Martinez, and Eliseo Escanillas, Jr. filed complaints against respondents Roselle Cinema, Silver Screen Corporation, and Vermy Trinidad for illegal dismissal, underpayment, non-payment of overtime pay, holiday pay, service incentive leave, and other monetary claims.
  • The complaints were consolidated and heard by the Labor Arbiter (LA) of the National Labor Relations Commission (NLRC) in Iloilo City.

Labor Arbiter’s Decision

  • The LA dismissed the complaints, ruling that petitioners were not illegally dismissed. The LA found that petitioners failed to substantiate their claims and that respondents provided substantial evidence showing that petitioners voluntarily terminated their employment.
  • The LA also denied petitioners' money claims, as documentary evidence showed that these claims had been properly paid.

NLRC’s Decision

  • On appeal, the NLRC reversed the LA’s decision, declaring that petitioners were illegally dismissed and ordering respondents to pay the monetary claims.
  • The NLRC found that respondents failed to provide clear and convincing evidence to support their defense and that petitioners’ filing of a case for illegal dismissal negated the claim of abandonment.

Court of Appeals’ Decision

  • Respondents filed a special civil action for certiorari with the Court of Appeals (CA), which reversed the NLRC’s decision and reinstated the LA’s decision.
  • The CA held that petitioners voluntarily left their jobs and that their money claims were unsupported by evidence.

Petitioners’ Arguments

  • Petitioners argued that the CA erred in concluding that the NLRC’s decision was unsupported by evidence, as it was respondents’ burden to prove the legality of the dismissal.
  • They also contended that the CA failed to clearly state the legal basis for overturning the NLRC’s award of wage differentials.
  • Additionally, petitioners claimed that the CA should have dismissed the petition for being filed late.

Respondents’ Arguments

  • Respondents maintained that petitioners voluntarily left their jobs without notice and were not dismissed. They provided specific dates when each petitioner last reported for work and explained the circumstances surrounding their departure.

Issue:

  1. Whether petitioners were illegally dismissed.
  2. Whether petitioners are entitled to their money claims.
  3. Whether the NLRC’s decision had become final and executory.

Ruling:

  • The Supreme Court ruled that petitioners were not illegally dismissed but voluntarily terminated their employment. Therefore, they were not entitled to separation pay and backwages.
  • The Court upheld the NLRC’s award of certain monetary claims (service incentive leave pay, 13th month pay, overtime pay, rest day premium, and holiday pay premium) for the year 1996, as respondents failed to prove that these benefits were paid.
  • The Court modified the NLRC’s decision, ordering respondents to pay petitioners the following amounts:
    • Edna Abad: P18,396.12 (including salary for January 16-31, 1997).
    • Joseph Martinez: P10,490.87.
    • Eliseo Escanillas, Jr.: P10,490.87.

Ratio:

  1. Burden of Proof in Illegal Dismissal Cases: The employer bears the burden of proving that the employee was not dismissed or, if dismissed, that the dismissal was legal. Failure to discharge this burden means the dismissal is unjustified and illegal.
  2. Voluntary Termination of Employment: Petitioners’ actions and the surrounding circumstances showed that they voluntarily terminated their employment. There was no evidence of formal dismissal or resignation, but their contemporaneous acts indicated voluntary departure.
  3. Filing of a Complaint for Illegal Dismissal: The mere filing of a complaint for illegal dismissal does not automatically prove that dismissal occurred. The surrounding circumstances and evidence must be considered.
  4. Monetary Claims: While petitioners were not entitled to separation pay and backwages due to voluntary termination, they were entitled to certain labor standard benefits for 1996, as respondents failed to prove these were paid.


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