Case Digest (G.R. No. 190216)
Facts:
The case involves Arnold F. Anib as the petitioner and Coca-Cola Bottlers Philippines, Inc. and/or Rhogie Feliciano as the respondents. Anib was employed by Coca-Cola Bottlers Philippines, Inc. as a helper starting March 3, 1993, and later became the supervisor of a mini warehouse located on Ayala St., Makati City. On March 20, 2005, a national inventory of the warehouse was conducted, which matched the figures in the Daily Stock Situation Report (DSSR) prepared by Anib. However, on April 23, 2005, the warehouse was padlocked due to the company's failure to pay rent, with the DSSR indicating 1,455 cases remaining in the warehouse. The warehouse was reopened on May 17, 2005, after the rental obligations were settled. A subsequent spot count revealed a stock shortage valued at P361,061.00. Anib was notified of this shortage on May 24, 2005, and was asked to explain the discrepancy. He requested additional time to respond due to his wife's illness. A re-inventory later i...
Case Digest (G.R. No. 190216)
Facts:
Employment and Assignment
- Petitioner Arnold F. Anib was employed as a helper by respondent Coca-Cola Bottlers Philippines, Inc. on March 3, 1993. He was later assigned to supervise the company's mini warehouse in Ayala St., Makati City.
Inventory and Shortage Discovery
- On March 20, 2005, a national inventory was conducted, and the results matched the Daily Stock Situation Report (DSSR) prepared by petitioner.
- On April 23, 2005, the warehouse was padlocked due to unpaid rentals. The DSSR for that day indicated 1,455 cases remained in the warehouse.
- On May 17, 2005, the warehouse was reopened after the rental issue was resolved. A spot count revealed a stock shortage valued at P361,061.00.
Investigation and Termination
- On May 24, 2005, petitioner was notified of the shortage and asked to explain. He requested time due to his wife's illness.
- A re-inventory on June 3, 2005, revealed a larger shortage of 1,412 cases worth P404,807.00.
- During the investigation, petitioner claimed ignorance of the shortage and stated he relied on the 3PL's delivery records.
- Further investigation uncovered irregularities, including unauthorized stock withdrawals and discrepancies in receipts. Petitioner admitted to some discrepancies and requested salary deductions to cover the shortages.
- On December 28, 2005, petitioner was terminated and subsequently filed a complaint for illegal dismissal.
Labor Arbiter and NLRC Decisions
- On March 31, 2008, the Labor Arbiter ruled that petitioner was validly dismissed but awarded him separation pay.
- On September 22, 2008, the NLRC reversed the Labor Arbiter's decision, declaring the dismissal illegal and ordering full backwages, separation pay, and attorney's fees.
Court of Appeals Proceedings
- Petitioner filed a petition for certiorari with the CA, which was dismissed on March 18, 2009, for procedural deficiencies, including failure to attach a certified true copy of the NLRC decision.
- Petitioner submitted a Compliance with supporting documents, but the CA merely noted it, as the petition had already been dismissed.
Issue:
- Whether the CA erred in dismissing the petition for certiorari based on technicalities.
- Whether petitioner violated the rule against forum shopping.
- Whether the NLRC erred in awarding separation pay instead of ordering reinstatement.
Ruling:
- The Supreme Court partly granted the petition. It set aside the CA's Resolutions and remanded the case to the CA for further proceedings.
- The Court held that the CA should not have dismissed the petition on mere technicalities, especially in labor cases where substantial justice is paramount.
- The Court also ruled that petitioner did not violate the rule against forum shopping, as the pending petition filed by respondent did not involve the same causes of action, issues, or reliefs.
Ratio:
- Technicalities in Labor Cases: Procedural rules should be relaxed in labor cases to serve substantial justice. The CA should have considered petitioner's Compliance and supporting documents.
- Forum Shopping: Petitioner did not violate the rule against forum shopping, as the pending petition by respondent was not similar in causes of action, issues, or reliefs.
- Separation Pay vs. Reinstatement: The NLRC's award of separation pay instead of reinstatement should be reviewed by the CA, considering the circumstances of the case.