Title
Arc-Men Food Industries Corp. vs. National Labor Relations Commission
Case
G.R. No. 127086
Decision Date
Aug 22, 2002
The Supreme Court held that separation pay is not due in the absence of constructive or illegal dismissal, nullifying the NLRC's order for such benefits due to grave abuse of discretion.
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Case Digest (G.R. No. 127086)

Facts:

  • Arc-Men Food Industries Corporation (AMFIC) and its President, Arcadio P. Mendoza, are the petitioners.
  • The case involves the National Labor Relations Commission (NLRC) and several private respondents, including Nicolas Famor, Jr.
  • On January 15, 1992, forty-seven AMFIC employees filed a complaint with the Department of Labor and Employment (DOLE) alleging violations of the Labor Standards Law.
  • Twenty-six of these employees were among the complainants.
  • A DOLE inspection occurred on January 27, 1992, but employees claimed they were ordered to stop working to avoid interviews.
  • Employees were barred from entering the premises unless they signed waivers to withdraw their complaints.
  • Twenty-one complainants signed waivers and returned to work; the remaining twenty-six considered themselves constructively dismissed as of January 28, 1992.
  • AMFIC argued that the employees were not dismissed but that the plant was temporarily shut down due to a lack of raw materials and repairs.
  • When the plant was ready to resume operations on February 21, 1992, AMFIC issued notices for employees to return, but the private respondents did not comply.
  • On January 31, 1992, the private respondents filed a complaint for illegal constructive dismissal and underpayment of wages.
  • The Executive Labor Arbiter ruled on September 30, 1992, that there was no basis for the claim of illegal dismissal.
  • The NLRC initially affirmed the Arbiter's decision but later modified it to order reinstatement without backwages.
  • AMFIC's motion for reconsideration led to the NLRC directing the company to pay separation benefits instead of reinstatement.
  • AMFIC filed a petition for certiorari, alleging grave abuse of discretion by the NLRC.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition for certiorari, declaring the NLRC's resolutions dated June 29, 1994, and October 11, 1996, null and void.
  • The Court reinstated...(Unlock)

Ratio:

  • The Supreme Court noted that both the Executive Labor Arbiter and the NLRC agreed that no constructive or illegal dismissal had occurred.
  • Evidence supported AMFIC's claim of a temporary shutdown due to a lack of raw materials.
  • The employees' failure to report for work after notification was not indicative of abandonment.
  • The Court emphasized that factual findings of quasi-judicia...continue reading

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