Title
Ala Mode Garments, Inc. vs. National Labor Relations Commission
Case
G.R. No. 122165
Decision Date
Feb 17, 1997
Employees barred from work after absence, deemed constructively dismissed; Court ruled illegal due to lack of evidence, due process violations, and awarded backwages, benefits.
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Case Digest (G.R. No. 122165)

Facts:

Background of the Case:

  • Petitioner, Ala Mode Garments, Inc., is a garments manufacturer and exporter.
  • Private respondents, Lucrecia V. Gaba and Elsa I. Melarpes, were employees of the petitioner, initially hired as sewers and later promoted to line leaders, each supervising 36 sewers.

Incident Leading to the Dispute:

  • On May 5 and 6, 1993, all line leaders, including private respondents, did not report for work.
  • Petitioner suspected a concerted action to boycott its operations and verbally required private respondents to submit written explanations for their absence.

Barring from Work:

  • On May 7, 1993, private respondents were not allowed to enter the company premises.
  • On May 10, 1993, private respondents submitted their explanation letters:
    • Gaba cited her child’s illness as the reason for her absence.
    • Melarpes cited her own illness due to pregnancy.

Management’s Response:

  • Despite the explanations, private respondents were not allowed to resume work.
  • Petitioner claimed it advised private respondents to await the management’s decision pending an investigation into whether their absence was an act of sabotage.
  • Notably, other line leaders who were also absent on May 5 and 6, 1993, were immediately allowed to return to work.

Filing of Complaint:

  • On May 17, 1993, private respondents filed complaints for illegal dismissal with the National Labor Relations Commission (NLRC).

Issue:

  1. Whether private respondents were illegally dismissed.
  2. Whether petitioner had reasonable grounds to suspect private respondents of sabotage.
  3. Whether the penalty of dismissal was too severe for the alleged infraction.
  4. Whether petitioner complied with the due process requirements in dismissing private respondents.
  5. Whether the NLRC erred in holding petitioner liable for backwages, holiday pay, service incentive leave pay, and attorney’s fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court dismissed the petition and affirmed the NLRC’s decision with modifications, ruling that private respondents were illegally dismissed and entitled to full backwages, holiday pay, service incentive leave pay, and attorney’s fees. The Court emphasized the importance of due process and the employer’s burden of proof in termination cases.


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