G.R. No. 142244 - Atlas Farms, Inc. vs. National Labor Relations Commission

Jaime O. dela Pea – Initially employed as a veterinary aide (from December 1975), later re-hired on July 8, 1989 as a feedmill operator with additional training duties.
Marcial I. Abion – Employed as a carpenter/mason and maintenance man starting October 8, 1990.

Terminated among several employees in July 1989.
Re-hired on July 8, 1989, with additional responsibilities.
On March 13, 1993, allegedly caught urinating and defecating on company premises (a date erroneously cited elsewhere).
Issued a formal notice by the farm manager requiring an explanation within 24 hours, which he refused to receive or respond to either verbally or in writing.
On March 20, 1993, received a notice of termination along with separation pay amounting to P13,918.67.
Worked continuously—seven days a week including holidays—without overtime, holiday pay, rest day pay, or service incentive leave; earning a daily wage of P180 (approximately P5,402 monthly).

Accused of causing clogging of the fishpond drainage due to improper disposal of grass and waste, resulting in damages running into several hundred thousand pesos.
Received a written notice requiring him to explain his actions, which he refused to accept.
Terminated on October 27, 1992, and acknowledged receipt of his separation pay.
Similarly worked seven days a week without the statutory additional benefits; earning a monthly salary of P4,500.

Both respondents filed separate complaints for illegal dismissal, alleging that their terminations were motivated by suspicions that they were leaders in a movement to form a union aimed at rivaling the existing management-dominated union.
Their initial cases were dismissed by the labor arbiter on the ground that they had not exhausted the grievance machinery provided in the Collective Bargaining Agreement (CBA).
Subsequently, the respondents refiled their cases before the NLRC in Region IV, after arguing that petitioner showed no willingness to engage in conciliation proceedings.
Petitioner argued that the existence of a CBA mandated that any disputes be resolved through the grievance machinery and eventual voluntary arbitration, thus questioning the jurisdiction of the labor arbiter and NLRC.
The NLRC reversed the labor arbiter’s dismissal finding the dismissals illegal, a ruling later affirmed—with modifications—by the Court of Appeals.
Petitioner’s subsequent petition for certiorari and motion for reconsideration were denied, with the appellate court modifying the awards and ordering petitioner to pay costs.

Whether the dismissals of Jaime O. dela Pea and Marcial I. Abion were carried out in accordance with due process and were for a valid cause under the company’s rules and regulations.
Whether failure to receive and respond to the formal notice properly deprived the respondents of their right to a hearing.

Whether the labor arbiter and the NLRC properly assumed jurisdiction over the illegal dismissal claims given the existing Collective Bargaining Agreement (CBA).
Whether the grievance machinery and voluntary arbitration process under the CBA should have been the exclusive forum for resolving the dispute.

Whether private respondents are entitled to full back wages from the date of dismissal until the promulgation of the decision.
Whether respondents should receive separation pay in lieu of reinstatement, especially considering the petitioner’s closure of its shop.
Whether petitioner should bear the costs of the suit.