Case Digest (G.R. No. 138094)
Facts:
The case involves Marilou Guanzon Apalisok (petitioner) and Radio Philippines Network (RPN) Station DYKC, along with its Station Manager George Suazo (respondents). On May 15, 1995, Apalisok, who was the Production Chief at RPN, received a memorandum from Branches Operations Manager Gilito Datoc. This memorandum requested her to provide a written explanation regarding allegations of her hostile actions towards RPN and her disrespectful behavior towards her superior, Suazo. In response, Apalisok submitted her explanation on May 16, 1995. Subsequently, on May 31, 1995, she received another memorandum from RPN's Administrative Manager, which informed her of her termination effective June 15, 1995. On June 5, 1995, Apalisok opted to waive her right to resolve the matter through RPN's grievance machinery as stipulated in the Collective Bargaining Agreement (CBA) and instead filed a complaint for illegal dismissal against RPN and Suazo before the National Labor Relations Co...
Case Digest (G.R. No. 138094)
Facts:
Employment and Initial Dispute:
- Marilou Guanzon Apalisok (petitioner) was the Production Chief of Radio Philippines Network (RPN) Station DYKC.
- On May 15, 1995, she received a memorandum from Branches Operations Manager Gilito Datoc, asking her to explain why no disciplinary action should be taken against her for alleged hostile acts towards RPN and disrespectful behavior towards her superior, Station Manager George Suazo.
- Petitioner submitted her written explanation on May 16, 1995.
Termination and Grievance Waiver:
- On May 31, 1995, petitioner received another memorandum from RPN's Administrative Manager, informing her of her termination effective June 15, 1995.
- On June 5, 1995, petitioner waived her right to resolve the case through RPN's grievance machinery under the Collective Bargaining Agreement (CBA) and opted to file a complaint for illegal dismissal before the National Labor Relations Commission (NLRC).
Voluntary Arbitration Agreement:
- On June 20, 1995, petitioner and respondents (RPN DYKC and George Suazo) signed a Submission Agreement to submit the issue of the validity of petitioner's dismissal to voluntary arbitration.
- Petitioner prayed for a declaration of invalid dismissal, separation pay, backwages, moral damages (P2,000,000), and exemplary damages (P500,000).
- Respondents argued that the voluntary arbitrator lacked jurisdiction and that petitioner was not illegally dismissed.
Voluntary Arbitrator's Decision:
- On October 18, 1995, the voluntary arbitrator ruled in favor of petitioner, declaring her dismissal invalid but awarding separation pay, backwages, moral and exemplary damages, service incentive leave pay, and attorney's fees instead of reinstatement due to strained relations.
Appeal to the Court of Appeals:
- Respondents filed a petition for certiorari before the Supreme Court, which referred the case to the Court of Appeals.
- The Court of Appeals nullified the voluntary arbitrator's award, ruling that petitioner's waiver of the grievance machinery also relinquished her right to voluntary arbitration.
Issue:
- Whether the Voluntary Arbitrator had jurisdiction over petitioner's complaint.
- Whether respondents are guilty of estoppel.
Ruling:
The Supreme Court ruled in favor of the petitioner:
- The Court of Appeals' decision was set aside, and the voluntary arbitrator's award was reinstated.
- The voluntary arbitrator had jurisdiction over the case because both parties agreed to submit the dispute to voluntary arbitration through the Submission Agreement.
- The Court found it unnecessary to address the issue of estoppel since the voluntary arbitrator's jurisdiction was established.
Ratio:
- Under Article 262 of the Labor Code, voluntary arbitrators have jurisdiction over labor disputes upon agreement of the parties.
- The Submission Agreement signed by both parties demonstrated their mutual consent to submit the dispute to voluntary arbitration.
- The Court of Appeals erred in ruling that petitioner's waiver of the grievance machinery also waived her right to voluntary arbitration. The parties' agreement to voluntary arbitration was valid and binding.
- The voluntary arbitrator's award was reinstated as it was based on valid jurisdiction and proper legal grounds.