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:
- Marilou Guanzon Apalisok, then Production Chief of Radio Philippines Network (RPN) Station DYKC, received a memorandum on May 15, 1995, from Branches Operations Manager Gilito Datoc.
- The memorandum requested a written explanation from petitioner for her alleged acts of hostility toward RPN and for displaying arrogant, disrespectful, and defiant behavior toward her superior, Station Manager George Suazo.
- On May 16, 1995, petitioner complied by submitting her answer to the memorandum.
Background of the Case
- On May 31, 1995, petitioner received another memorandum from RPN’s Administrative Manager informing her of her termination effective June 15, 1995.
- By June 5, 1995, petitioner communicated her decision to waive the right to resolve the dispute through the grievance machinery provided in the Collective Bargaining Agreement (CBA), opting instead to seek redress before the proper government forum.
- Following her decision, petitioner filed a complaint for illegal dismissal before the National Labor Relations Commission, Regional Arbitration Branch of Region 7, which later referred her case to the National Conciliation and Mediation Board.
Termination and Subsequent Actions
- On June 20, 1995, through a Submission Agreement signed by the counsels of both parties, petitioner and respondents agreed to submit the dispute regarding the validity of petitioner’s dismissal to voluntary arbitration.
- In her position paper submitted before the voluntary arbitrator, petitioner prayed that her dismissal be declared invalid and that she be awarded separation pay, backwages, and other benefits under the Labor Code since reinstatement was deemed impractical due to strained relations.
- Petitioner also claimed moral damages of P2,000,000.00 and exemplary damages of P500,000.00.
Submission to Voluntary Arbitration
- On October 18, 1995, the voluntary arbitrator rendered an award in favor of petitioner, declaring her dismissal invalid.
- Considering that reinstatement was impractical, the award directed respondents to pay petitioner a total of P411,126.76, which was itemized as follows:
- Separation Pay – P138,700.95
- Backwages – P88,817.00
- Moral and Exemplary Damages – P100,000.00
- Service Incentive Leaves – P46,233.65
- Attorney’s Fees (10%) – P37,375.16
- All other claims by the petitioner were expressly denied.
Award Issued by the Voluntary Arbitrator
- Respondents filed a motion for reconsideration of the arbitration award, which was denied on November 21, 1995.
- They then petitioned for certiorari before this Court (G.R. No. 122841), which was referred by the Third Division to the Court of Appeals based on prior jurisprudence (e.g., Luzon Development Bank v. Association of Luzon Development Bank Employees).
- The Court of Appeals ruled that petitioner’s option not to avail of the grievance machinery amounted to relinquishing her right to voluntary arbitration, thereby nullifying the arbitration award through its Decision on October 30, 1998.
- Petitioner’s later Motion for Reconsideration of the Court of Appeals Decision was denied by Resolution on February 26, 1999, prompting the present petition for review.
Respondents’ Challenge and Subsequent Appeals
Issue:
- Petitioner argued that her waiver of the internal grievance procedure did not equate to the relinquishment of her right to voluntary arbitration, citing Article 262 of the Labor Code of the Philippines.
- Respondents contended that the petitioner’s decision effectively converted an unresolved grievance into a resolved one, thereby depriving the voluntary arbitrator of jurisdiction.
Whether the voluntary arbitrator had jurisdiction over petitioner’s complaint.
- Petitioner maintained that even if jurisdiction were in doubt, a party who voluntarily submits to arbitration should not later challenge the arbitrator’s authority.
Whether respondents are estopped from questioning the authority of the voluntary arbitrator.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)