Title
Associated Anglo-American Tobacco Corp. vs. Lazaro
Case
G.R. No. 63779
Decision Date
Oct 27, 1983
Employee dismissed over alleged shortage; reinstated with backwages limited to 3 years by Supreme Court for pragmatic justice.
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Case Digest (G.R. No. 63779)

Facts:

  1. Employment Details:

    • Jaime Sambajon was employed by Associated Anglo-American Tobacco Corporation as a driver-agent from October 1968 to September 1973, earning P300 a month.
    • On October 1, 1973, he was promoted to promotional dealer with a monthly salary of P740.
  2. Dismissal and Complaint:

    • On February 11, 1974, the company filed an application to dismiss Sambajon due to an alleged shortage in his accounts amounting to P2,536.25.
    • On March 11, 1974, Sambajon filed a complaint for reinstatement, backwages, and overtime pay.
  3. Labor Arbiter's Decision:

    • On October 30, 1975, the Labor Arbiter ordered Sambajon's reinstatement with backwages from March 1, 1974, at the rate of P740 per month.
  4. NLRC Resolution:

    • On March 22, 1976, the National Labor Relations Commission (NLRC) dismissed the company's appeal because it was not under oath, as required by its rules.
  5. Acting Secretary of Labor's Order:

    • On December 13, 1976, Acting Secretary Amado G. Inciong ordered Sambajon's dismissal due to the alleged shortage.
  6. Office of the President's Decision:

    • On December 22, 1982, the Office of the President nullified Acting Secretary Inciong's order and affirmed the Labor Arbiter's decision.
  7. Writ of Execution:

    • The Executive Labor Arbiter issued a writ of execution for P106,064.20, covering backwages, thirteenth-month pay, and living allowances as of March 31, 1983.
    • The company posted a supersedeas bond of P162,000 to stay execution.
  8. Petition for Certiorari:

    • The company filed a petition for certiorari, not contesting Sambajon's reinstatement but seeking to limit backwages to three years.

Issue:

The primary issue in this case is whether the backwages of a reinstated employee should be limited to three (3) years.

Ruling:

The Supreme Court ruled that, in the interest of pragmatic and expeditious justice, the backwages should be limited to three years. The Court modified the decision under review, granting Sambajon reinstatement and backwages equivalent to three years' pay.

Ratio:

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