Case Digest (G.R. No. L-5594)
Facts:
The case involves Atok-Big Wedge Mining Co., Inc. as the petitioner and Atok-Big Wedge Mutual Benefit Association as the respondent. The events leading to the case began on February 28, 1951, when Aklayan Bayo, a laborer employed by Atok-Big Wedge Mining Co., was apprehended by a company policeman. Bayo was found with a bag of gold ores concealed under his left armpit during the night, which led to his suspension and subsequent dismissal from the company. The matter was brought before the Court of Industrial Relations, which initially authorized Bayo's dismissal in a decision dated December 8, 1951. However, upon a motion for reconsideration, the court, sitting en banc, reversed its earlier decision on March 4, 1952. The court ordered the reinstatement of Aklayan Bayo and mandated the company to pay him back wages from the date of his dismissal until his actual reinstatement. The mining company ...
Case Digest (G.R. No. L-5594)
Facts:
Parties Involved:
- Petitioner: Atok-Big Wedge Mining Co., Inc.
- Respondent: Atok-Big Wedge Mutual Benefit Association (representing Aklayan Bayo).
Incident Leading to Dismissal:
- Aklayan Bayo, a laborer employed by the petitioner, was allegedly caught by a company policeman on February 28, 1951, concealing a bag of gold ores under his left armpit under the cover of darkness.
Initial Action by the Company:
- The petitioner suspended and subsequently dismissed Bayo based on the alleged breach of trust and violation of company regulations.
Judicial Proceedings:
- The case was brought before the Court of Industrial Relations (CIR), which initially authorized the dismissal in its decision dated December 8, 1951.
- Upon motion for reconsideration, the CIR en banc reversed its decision on March 4, 1952, ordering Bayo's reinstatement and payment of back wages from February 28, 1951, until his actual reinstatement.
Criminal Case:
- Bayo was prosecuted for theft before the Justice of the Peace Court of Itogon, Mountain Province, but was acquitted.
Petitioner's Argument:
- The petitioner contended that Bayo's acquittal in the criminal case did not preclude his dismissal, as the facts showed he was guilty of a breach of trust.
CIR's Finding:
- The CIR found no evidence to support the alleged breach of trust or any sufficient reason to distrust Bayo.
Issue:
- Whether the Court of Industrial Relations erred in ordering the reinstatement of Aklayan Bayo and awarding him back wages.
- Whether the acquittal of Bayo in the criminal case precludes his dismissal by the employer.
- Whether the petitioner's dismissal of Bayo was justified based on the alleged breach of trust.
Ruling:
The Supreme Court affirmed the resolution of the Court of Industrial Relations, ordering the reinstatement of Aklayan Bayo and the payment of his back wages. The Court held that the CIR's finding of no evidence supporting the alleged breach of trust was a factual determination that could not be reviewed or altered in the present case.
Ratio:
Factual Findings of the CIR:
- The Supreme Court emphasized that the CIR's finding of no evidence supporting the alleged breach of trust was a factual determination, which the Court could not review or alter in the absence of grave abuse of discretion.
Acquittal in Criminal Case:
- The Court ruled that Bayo's acquittal in the criminal case was not determinative of his dismissal. However, the petitioner failed to present sufficient evidence to justify the dismissal based on breach of trust.
Employer's Discretion vs. Evidence:
- While an employer has the discretion to dismiss an employee for breach of trust, such discretion must be supported by substantial evidence. In this case, the petitioner failed to provide such evidence.
Non-Interference with CIR's Factual Determinations:
- The Supreme Court reiterated the principle that it would not interfere with the factual findings of the CIR unless there was a clear showing of grave abuse of discretion.