Title
Antipolo Highway Lines, Inc. vs. Inciong
Case
G.R. No. L-38532
Decision Date
Jun 27, 1975
Crisostomo, dismissed for alleged fraud, filed for separation pay and reinstatement. NLRC ruled in his favor, ordering reinstatement with limited back wages, upheld by the Supreme Court.

Case Digest (G.R. No. L-38532)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner:
      • Antipolo Highway Lines, Inc.
      • Francisco L. de Jesus, its president and general manager.
    • Respondents:
      • The National Labor Relations Commission (NLRC) and its members.
      • Other respondents including the Secretary of Labor and specific NLRC officials.
    • Employee Involved:
      • Crisanto Crisostomo, former inspector and later chief inspector of the company.
  • Employment and Dismissal
    • Crisostomo’s Employment History:
      • Initially employed as an inspector and subsequently promoted to chief inspector by the bus company.
    • Grounds for Dismissal:
      • Dismissed on August 11, 1972.
      • Alleged involvement in a syndicate that defrauded the company to the tune of approximately ten thousand pesos.
      • Accused of being part of a conspiracy with other employees (bus conductors, drivers, and inspectors) to manipulate bus ticket issuance and misappropriate company funds.
    • Subsequent Criminal and Administrative Proceedings:
      • Crisostomo filed an estafa complaint against De Jesus.
      • The company filed a counter-charge for estafa through falsification of commercial documents.
      • The investigating fiscal dismissed both charges due to insufficient evidence in resolutions dated February 12, 1973.
  • NLRC Proceedings
    • Initial Filing and Mediation:
      • Crisostomo commenced a complaint with the NLRC on January 15, 1973, alleging arbitrary dismissal and seeking separation pay under labor laws.
      • The case was assigned to a mediator, Eusebio M. Jimenez, who set a schedule for fact-finding conferences.
      • Multiple conferences were held with appearances by Crisostomo and representatives of the company, with issues placed in abeyance due to the pendency of the estafa case.
    • Reopening and Hearings:
      • After the dismissal of the estafa case, Crisostomo asked for the reopening of his NLRC case on February 20, 1973.
      • Hearings were rescheduled on various dates (February 26, March 1, March 7, and March 15, 1973) with inconsistent appearances by the company’s representatives.
      • Crisostomo filed an amended complaint on March 12, 1973, renewing his claim for reinstatement and back wages, specifying a monthly wage of P309 from a date following dismissal.
    • Transition to Compulsory Arbitration:
      • When attempts at amicable settlement failed during the mediation process, the case was returned to the NLRC for compulsory arbitration.
      • On April 12, 1973, the company, through counsel, submitted a memorandum arguing lack of jurisdiction of the NLRC and asserting that the dismissal was justified (for breach of trust).
      • Supporting documents included affidavits from Francisco de Jesus and bus inspector Enrique Cruz, along with copies of the criminal complaint, fiscal office resolution, and related annexes.
  • Arbitrator’s Decision and Aftermath
    • Appointment of the Arbitrator:
      • Francisco G. Jose was designated as the compulsory arbitrator on April 25, 1973.
      • He was instructed to resolve the case within twenty working days, pursuant to NLRC Rules and Regulations.
    • Hearings and Evidence Presented:
      • Multiple hearings were conducted between May and June 1973.
      • Crisostomo consistently appeared at the hearings, while the company’s legal representation was irregular, with limited appearances.
    • Award Rendered:
      • On June 25, 1973, the arbitrator issued an award ordering the reinstatement of Crisostomo with full back wages amounting to P3,090 for a period of ten months, computed from August 11, 1972.
      • The order was confirmed by the NLRC on September 7, 1973, and later affirmed by the Secretary of Labor in a resolution dated March 19, 1974.
    • Petition for Certiorari:
      • The company and De Jesus later filed a special civil action for certiorari, challenging the NLRC order on grounds of due process violations (lack of opportunity to present evidence) and alleged grave abuse of discretion.
      • They abandoned their earlier contention regarding the NLRC’s jurisdiction but maintained that the proceedings denied them a fair hearing.
    • Supplementary Resolution on Estafa Charges:
      • A related resolution addressed separate estafa charges against Crisostomo.
      • Evidence by the company, including affidavits and documentary evidence (but lacking direct testimony from co-conspirators and original documents in complete form), was found to be insufficient to establish a prima facie case for estafa, leading to a recommendation for dismissal of the charge.

Issues:

  • Due Process Concerns
    • Whether the NLRC proceedings denied Antipolo Highway Lines, Inc. and Francisco L. de Jesus the opportunity to present all their evidence.
    • Whether the summary nature of the NLRC procedures deprived the petitioners of their right to a full hearing.
  • Jurisdiction and Procedural Validity
    • Whether the NLRC exercised jurisdiction properly over Crisostomo’s complaint.
    • Whether the technical rules of court practice, procedure, and evidence were justifiably relaxed in the summary proceedings before the NLRC.
  • Computation of Back Wages
    • Whether Crisostomo is entitled to back wages from the date of dismissal until his reinstatement.
    • Whether the award should be limited to ten months of back wages (the sum of P3,090) as opposed to a computation extending to the actual date of reinstatement.
  • Evidentiary Basis for Dismissal and Charges
    • Whether the evidence adduced (notably the affidavits regarding involvement in a syndicate and alleged dishonesty) was sufficient to justify the dismissal or to sustain the estafa charges.
    • Whether hearsay and uncorroborated evidence should have been given weight in establishing the company’s claims.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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