Case Digest (G.R. No. L-59651)
Facts:
The case involves Akay Printing Press as the petitioner and the Minister of Labor and Employment, along with private respondents Nelson Olayta and Jose Polpol, as respondents. The events leading to this case began in August 1978 when Akay Printing Press issued a memorandum to Olayta and Polpol, who were employed as helpers, addressing their alleged negligence in printing customer brands on polybags. The memorandum warned them that a repetition of such negligence could lead to termination. However, the private respondents refused to accept the memorandum and were subsequently dismissed without the required clearance from the Ministry of Labor and Employment (MOLE). Following their dismissal, Olayta and Polpol filed a complaint for illegal dismissal with the MOLE. The Regional Director for the National Capital Region conducted hearings, during which only the complainants submitted position papers. On July 31, 1979, the Regional Director ruled that the private respondents had be...
Case Digest (G.R. No. L-59651)
Facts:
Employment and Alleged Negligence
Private respondents Nelson Olayta and Jose Polpol were employed as helpers by petitioner Akay Printing Press. In August 1978, the petitioner issued a memorandum to Olayta and Polpol, warning them about their alleged negligence in printing a customer's brand on polybags, which led to the rejection of the printed articles. The memorandum warned that a repetition of such negligence could result in the termination of their services.Refusal to Receive Memorandum and Dismissal
Private respondents refused to receive the memorandum. Consequently, they were dismissed without obtaining prior clearance from the Ministry of Labor and Employment (MOLE).Complaint for Illegal Dismissal
Private respondents filed a complaint for illegal dismissal with the MOLE. The Regional Director of the National Capital Region conducted hearings and required both parties to submit position papers. Only the complainants complied.Regional Director's Order
On July 31, 1979, the Regional Director issued an order finding that Olayta and Polpol were illegally dismissed. The petitioner was ordered to reinstate them with backwages.Petitioner's Motion for Reconsideration
The petitioner filed a motion for reconsideration, claiming that private respondents had abandoned their work and were not dismissed. The motion was treated as an appeal and elevated to the MOLE.MOLE's Affirmation of the Order
On May 25, 1981, the Deputy Minister of Labor affirmed the Regional Director's order. The petitioner then filed another motion for reconsideration, this time challenging the jurisdiction of the Regional Director for the first time. The motion was denied.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Estoppel by Laches
A party cannot invoke the jurisdiction of a court or quasi-judicial body to secure affirmative relief and later repudiate that same jurisdiction after an adverse decision. This principle is rooted in public policy and prevents the undesirable practice of questioning jurisdiction only after losing on the merits.Binding Nature of Factual Findings
Factual findings of quasi-judicial agencies, when supported by substantial evidence, are conclusive and binding on the courts. In this case, the evidence supported the finding of illegal dismissal.Limitation on Backwages
While reinstatement with backwages is a remedy for illegal dismissal, the Court has consistently limited backwages to three years to balance the interests of both employers and employees.