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:
- Petitioner: Atok-Big Wedge Mining Co., Inc.
- Respondent: Atok-Big Wedge Mutual Benefit Association
- Employee Involved: Aklayan Bayo, a laborer of the petitioner
Parties and Background
- 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.
The Incident
- 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.
Employer’s Action
- 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.
Judicial and Administrative Proceedings
- 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.
Criminal Prosecution Related to the Incident
- 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.
Petitioner’s Arguments
- 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.
Findings of the Court of Industrial Relations
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)