Case Digest (G.R. No. 10051)
Facts:
Ama Computer College, Inc. v. Ely Garcia and Ma. Teresa Balla, G.R. No. 166703, April 14, 2008, Supreme Court Third Division, CHICO-NAZARIO, J., writing for the Court. Petitioner AMA Computer College, Inc. (ACC) sought review of the Court of Appeals' decision affirming the National Labor Relations Commission (NLRC) which in turn affirmed the Labor Arbiter's ruling that respondents Ely Garcia and Ma. Teresa Balla were illegally dismissed.Garcia was hired by ACC on January 6, 1988, became probationary Library Aide on May 15, 1989, and regular on February 15, 1990. Balla was hired August 1, 1996 as a Social Worker, later Guidance Assistant, and became regular on June 2, 1997. On March 21, 2000 ACC's Human Resource Director served a notice informing Garcia, Balla and 52 others that, effective April 21, 2000, their positions were found “no longer necessary” under a company streamlining program.
Garcia and Balla filed complaints for illegal dismissal before the Labor Arbiter, praying for backwages, separation pay, 13th month pay and attorney’s fees, alleging bad faith and lack of fair criteria in the streamlining. ACC defended the terminations as legitimate streamlining/redundancy/retrenchment. On March 25, 2002 the Labor Arbiter declared the dismissals illegal and ordered backwages and additional separation pay.
ACC appealed to the NLRC, which on May 20, 2003 affirmed the Labor Arbiter’s finding of illegal dismissal but deleted awards of 13th month pay, service incentive leave pay and cost of living allowance. The NLRC denied reconsideration on October 30, 2003. ACC then filed a Petition for Certiorari under Rule 65 with the Court of Appeals, which on August 30, 2004 affirmed the NLRC, holding that certiorari is limited to grave abuse of discretion and should not reweigh evidence. The CA denied ACC’s motion for reconsideration on December 1, 2004.
ACC filed a Rule 45 petition for review with the Supreme Court. The Court required respondents to comment; they failed to do so despite show-cause orders and fines. ...(Subscriber-Only)
Issues:
- Did the Court of Appeals gravely err in limiting its review in ACC’s Rule 65 petition to questions of jurisdiction and grave abuse of discretion and thereby refusing to re-evaluate the sufficiency of evidence?
- Did ACC prove redundancy or retrenchment as lawful grounds for dismissing Garcia and Balla?
- Did ACC apply fair and reasonable selection criteria (e.g., less preferred status, efficiency, seniority) in cho...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)