Facts:

Daniel C. Aspacio was employed by the Pepsi Cola Bottling Company of the Philippines starting May 10, 1975. During his tenure, he developed malignant hypertension, which led to his retirement on June 1, 1976, upon his company's physician's recommendation. Aspacio received retirement benefits totaling P6,820.00 and P700.00 for his 13th month pay. Following his retirement, he filed a complaint with the Region IV office of the Department of Labor, claiming an additional P7,535.62 for the remaining retirement benefits and commissions owed under the collective bargaining agreement. The company argued against this claim, producing an alleged quitclaim that Aspacio disputed, claiming his signature on the document was not authentic.

On March 18, 1977, the Officer-in-Charge of the Region, Vicente Leogardo, Jr., dismissed Aspacio’s case, citing procedural rules under the Labor Code. Aspacio appealed to the Bureau of Labor Relations, contesting the dismissal, and on July 5, 1977,

...

Facts:

Background of Employment and Health Condition

• Daniel C. Aspacio was employed by Pepsi Cola Bottling Company of the Philippines beginning on May 10, 1975.
• During his employment, he contracted malignant hypertension, which affected his ability to work.

Retirement and Initial Benefits

• On June 1, 1976, based on the recommendation of the company physician, Aspacio was retired.
• Upon retirement, he received retirement benefits amounting to P6,820.00 and an additional P700.00 as 13th month pay.

Filing of the Complaint and Claims Raised

• Aspacio filed a complaint with the Region IV office of the Department of Labor seeking:
• The recovery of the balance of his retirement benefits totaling P7,535.62; and
• Payment of unpaid commissions due upon retirement as provided under the collective bargaining agreement.
• The collective bargaining agreement provided specific guidelines for commission computation, indicating a daily average commission and enumerating commission rates per case based on the employee’s classification.
• Aspacio alleged that, aside from the retirement benefits, he was due commissions which, according to the agreement, were to be computed on designated periods (not exclusively at retirement).

Procedural History Prior to the Petition

• The Regional Director of the Department of Labor, Hon. Vicente Leogardo, Jr., initially dismissed the case, denying its certification to the labor arbiter based on Section 7(a) and (c), Rule XII, Book V of the Implementing Rules and Regulations of the Labor Code.
• Aspacio appealed to the Bureau of Labor Relations, challenging the authenticity of his signature on the alleged quitclaim and release submitted by the company.
• Acting Director Francisco Estrella set aside the earlier dismissal on July 5, 1977, and certified the case for compulsory arbitration, leading to a hearing before a labor arbiter.
• On August 4, 1977, the labor arbiter rendered a decision ordering Pepsi Cola Bottling Company to pay Aspacio P7,535.62 covering both the balance of retirement benefits and the commission due, with the computation of the latter to be made by the NLRC Socio-Economic Analyst.
• The company appealed the decision to the National Labor Relations Commission (NLRC), and subsequent orders and appeals ensued:
• The Second Division of the NLRC dismissed the company’s appeal on February 13, 1978.
• The Secretary of Labor later reviewed the matter.
• A writ of execution was issued to effectuate collection of the award, although subsequent orders temporarily released and then required the return of the collected funds due to a stay of execution.
• Procedural maneuvers by both parties continued:
• Aspacio filed an appeal within the reglementary period despite the partial satisfaction of the labor arbiter’s decision.
• The Deputy Minister of Labor ultimately issued an order on July 18, 1978, which:
• Affirmed the award of retirement benefits amounting to P7,535.62; and
• Dismissed the claim for unpaid commissions, finding that there was insufficient evidence.

Evidentiary Developments and the Release Document

• The company introduced a notarized release or quitclaim, which purportedly absolved it from any further claims by Aspacio arising from his employment, including any unpaid commissions.
• The presence of this release was given significant evidentiary weight in the proceedings.

Issue:

Validity of the Deputy Minister’s Reversal on Findings of Fact

• Whether the Deputy Minister of Labor validly reversed the labor arbiter’s findings of fact that were purportedly supported by substantial evidence.

Sufficiency and Specification of the Claim for Unpaid Commissions

• Whether the claim for unpaid commissions was properly presented with clear, specific details (such as the approximate amount, the due period, and the number and kind of bottles sold) and supported by convincing evidence.

Procedural Validity of the Appeal by the Respondent Company

• Whether the appeal filed by the respondent company should have been dismissed on the ground that the appeal fee was not paid, considering the provisions of the Rules and Regulations Implementing the Labor Code.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)