Title
Atok-Big Wedge Mining Co., Inc. vs. Atok-Big Wedge Mutual Benefit Association
Case
G.R. No. L-5594
Decision Date
May 15, 1953
Aklayan Bayo, accused of theft and dismissed by Atok-Big Wedge Mining, was acquitted criminally. The Court of Industrial Relations ordered his reinstatement with back wages, citing insufficient evidence of breach of trust, upheld by the Supreme Court.
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Case Digest (G.R. No. L-5594)

Facts:

    Parties and Background

    • Petitioner: Atok-Big Wedge Mining Co., Inc.
    • Respondent: Atok-Big Wedge Mutual Benefit Association
    • Employee Involved: Aklayan Bayo, a laborer of the petitioner

    The Incident

    • On February 28, 1951, Aklayan Bayo was apprehended by the company's policeman.
    • He was found concealing a bag containing gold ores under his left armpit, allegedly taking advantage of the cover of darkness.

    Employer’s Action

    • Following the incident, the company suspended and subsequently dismissed Aklayan Bayo.
    • The dismissal was based on an alleged breach of trust, implying misconduct on the part of Bayo.

    Judicial and Administrative Proceedings

    • The propriety of the dismissal was first examined by the Court of Industrial Relations.
    • On December 8, 1951, the court initially authorized the dismissal.
    • Upon motion for reconsideration, the same court, in its in banc resolution dated March 4, 1952, reversed its earlier decision.
    • The reversal ordered the reinstatement of Aklayan Bayo.
    • The order further mandated the payment of his back wages from February 28, 1951 until his actual reinstatement.

    Criminal Prosecution Related to the Incident

    • Aklayan Bayo was prosecuted for theft before the Justice of the Peace Court of Itogon, Mountain Province.
    • Despite the prosecution, he was ultimately acquitted by the justice of the peace.

    Petitioner’s Arguments

    • The petitioner contended that the dismissal did not depend solely on the outcome of the criminal case.
    • It was argued that as long as factual circumstances (i.e., the concealment of gold ores) pointed to a breach of trust, the dismissal was justified.
    • The petitioner emphasized that the mere possession of gold ores, even after acquittal, was sufficient to validate the dismissal under company regulations and general law.

    Findings of the Court of Industrial Relations

    • The lower tribunal determined that there was insufficient evidence to substantiate the breach of trust allegation against Aklayan Bayo.
    • This factual finding was pivotal in ordering his reinstatement and the payment of back wages.

Issue:

  • Whether the allegation of breach of trust based on the concealment of gold ores was sufficient to justify the dismissal of Aklayan Bayo.
  • Whether the acquittal of Aklayan Bayo in the criminal prosecution for theft should influence or override the employer’s decision to dismiss him.
  • The degree to which an appellate court may review and interfere with the factual determinations reached by the Court of Industrial Relations.
  • Whether an employer may rely on factual allegations absent definitive evidence to effect dismissal of an employee.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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