Case Digest (G.R. No. 166703)
Facts:
The case involves AMA Computer College, Inc. (ACC) as the petitioner and Ely Garcia and Ma. Teresa Balla as the respondents. The events leading to the case began when Garcia was hired as a janitress on January 6, 1988, and later transitioned to a probationary Library Aide on May 15, 1989, eventually becoming a regular employee on February 15, 1990. Balla was hired as a Social Worker on August 1, 1996, and became a regular employee on June 2, 1997, after serving as a Guidance Assistant. On March 21, 2000, ACC's Human Resource Director, Anthony R. Vince Cruz, informed Garcia, Balla, and 52 other employees of their termination due to a manpower review aimed at streamlining operations in light of the prevailing economic conditions. The termination was effective April 21, 2000. Following their dismissal, Garcia and Balla filed a complaint with the Labor Arbiter, claiming illegal dismissal and seeking backwages, separation pay, and attorney's fees. They argued that ACC'...
Case Digest (G.R. No. 166703)
Facts:
Employment Background:
- Ely Garcia: Hired as a janitress by AMA Computer College, Inc. (ACC) on 6 January 1988. Her employment status changed to probationary Library Aide on 15 May 1989, and she became a regular employee on 15 February 1990.
- Ma. Teresa Balla: Hired as a Social Worker by ACC on 1 August 1996. She later became a Guidance Assistant and was regularized on 2 June 1997.
Termination:
- On 21 March 2000, ACC informed Garcia, Balla, and 52 other employees of their termination, citing economic difficulties and the need to streamline operations. The termination was effective 21 April 2000.
- ACC claimed that the functions of Garcia (Library Aide) and Balla (Guidance Assistant) could be handled by existing staff, making their positions redundant.
Complaint:
- Garcia and Balla filed a complaint for illegal dismissal, seeking separation pay, 13th month pay, and attorney’s fees. They argued that ACC’s streamlining program lacked fair criteria and was done in bad faith.
Labor Arbiter’s Decision:
- On 25 March 2002, the Labor Arbiter ruled that Garcia and Balla were illegally dismissed and ordered ACC to pay backwages and separation pay. The 13th month pay, service incentive leave pay, and cost of living allowance were not awarded.
NLRC Decision:
- On 29 May 2003, the NLRC affirmed the Labor Arbiter’s decision but deleted the awards for 13th month pay, service incentive leave pay, and cost of living allowance.
Court of Appeals Decision:
- On 30 August 2004, the Court of Appeals affirmed the NLRC’s decision, holding that ACC failed to prove valid grounds for dismissal.
Supreme Court Petition:
- ACC filed a Petition for Review on Certiorari, arguing that the Court of Appeals erred in sustaining the finding of illegal dismissal and in not recognizing redundancy as a valid ground for termination.
Issue:
- Whether the Court of Appeals erred in affirming the NLRC’s finding of illegal dismissal.
- Whether ACC validly terminated Garcia and Balla on the grounds of redundancy or retrenchment.
- Whether the Court of Appeals properly limited its review to the issue of grave abuse of discretion by the NLRC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
The Supreme Court upheld the decisions of the lower courts, finding that ACC failed to prove valid grounds for the dismissal of Garcia and Balla. The termination was deemed illegal, and ACC was ordered to pay backwages and separation pay. The Court also reiterated the limited scope of judicial review in certiorari proceedings and the need for employers to substantiate claims of redundancy or retrenchment with sufficient evidence.