Case Digest (G.R. No. 121439) Core Legal Reasoning Model
Facts:
In the case of Aklan Electric Cooperative Incorporated (AKELCO) vs. National Labor Relations Commission, Rodolfo M. Retiso and 165 others, the petitioner, AKELCO, sought certiorari against the public respondent, NLRC, concerning their decisions dated April 20, 1995, and July 28, 1995. The background of the case traces back to claims made by Rodolfo M. Retiso and his fellow complainants against AKELCO, the management represented by Atty. Leovigildo Mationg, and Manuel Calizo.
The complaints were consolidated claims for unpaid salaries, wages, 13th-month pay, ECOLA, and other fringe benefits including allowances. Initially, prior to the temporary transfer of AKELCO's office from Lezo Aklan to Amon Theater, Kalibo, employees were paid their salaries until a resolution on January 22, 1992, forced the office transfer due to safety concerns. Some employees reported to Lezo despite the transfer, continuing to receive salaries from January to May 1992. However, from June 16, 1992,
Case Digest (G.R. No. 121439) Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- The case involves petitioner Aklan Electric Cooperative, Inc. (AKELCO) and private respondents (Rodolfo M. Retiso and 165 others), with the National Labor Relations Commission (NLRC) acting as the public respondent whose decision is being assailed.
- The consolidated claims cover wage disputes including unpaid salaries, 13th month pay, ECOLA, and other fringe benefits.
- Petitioner sought certiorari and prohibition with a prayer for a temporary restraining order to halt the execution of the NLRC decision ordering payment of wages.
- Chronology and Operational Developments
- In January 1992, pursuant to concerns that the main office in Lezo was dangerous, AKELCO’s Board of Directors resolved to temporarily transfer its operations to the Amon Theater in Kalibo, following the recommendation of Project Supervisor Atty. Leovigildo Mationg.
- Despite the transfer order, a majority of employees, including the complainants, continued to report to work at the original Lezo office, where they were regularly paid until May 1992.
- On February 11, 1992, an unnumbered resolution was passed by the Board withdrawing the temporary transfer, instructing daily operations to revert to the Lezo office.
- From June 16, 1992 to March 18, 1993, those who continued to report at Lezo were not paid their salaries, while service resumed and salaries were paid starting March 19, 1993.
- Allegations and Claims of the Private Respondents
- Private respondents claimed that they were owed wages for work rendered during the period from June 16, 1992 to March 18, 1993 despite management’s orders.
- They based their claim on evidence including:
- A letter dated April 7, 1993, from office manager Pedrito L. Leyson addressed to General Manager Atty. Leovigildo T. Mationg.
- A memorandum from Atty. Mationg dated April 14, 1993, offering to recommend the payment of their backwages.
- Their own computations of unpaid wages, which they submitted as evidence.
- Respondents’ Contentions Against the Private Respondents’ Claims
- Petitioner contended that the private respondents voluntarily abandoned or defied the lawful order to transfer to the Kalibo office, which is a classic case of “no work, no pay.”
- It was further argued that the alleged work done at the Lezo office after the transfer order could not justify the claim for wages during the period in which AKELCO’s operation had effectively moved to Kalibo.
- The petitioner also maintained that the alleged admission by the office manager was self-serving and did not establish that compensable service had actually been rendered.
- Procedural History and Additional Developments
- A Labor Arbiter initially rendered a decision dismissing the wage claims on February 25, 1994.
- On appeal, the NLRC Fourth Division reversed the labor arbiter’s findings and ordered AKELCO to pay the wages amounting to P6,485,767.90, basing its decision on the evidence submitted by the private respondents.
- A motion for reconsideration was filed by petitioner but was denied by the NLRC in a resolution dated July 28, 1995.
- Petitioner then elevated the case to the Court alleging grave abuse of discretion committed by the NLRC in reversing the factual findings and applying the “no work, no pay” principle contrary to the evidentiary record.
Issues:
- Whether public respondent NLRC committed grave abuse of discretion by:
- Reversing the factual findings of the Labor Arbiter that held that private respondents, by defying a lawful transfer order, were not entitled to wages under the “no work, no pay” principle.
- Accepting as substantial evidence private respondents’ own computations and the letter from office manager Leyson, despite its potential bias.
- Whether the evidence was sufficient to establish that private respondents rendered compensable services at the Kalibo office during the period from June 16, 1992 to March 18, 1993.
- Whether the administration’s act of temporarily transferring the business operations from Lezo to Kalibo, including the removal of equipment, records, and facilities, negated any claim for wages for work allegedly performed at the former office.
- Whether the petition should be granted on the ground that the NLRC exceeded its jurisdiction by reexamining factual determinations that were supported by substantial evidence, or that it misappreciated the evidence to such an extent as to constitute a grave abuse of discretion.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)