Facts:

The case of Nicanor Baltazar vs. San Miguel Brewery, Inc. (G.R. No. L-23076) arose from the employment of Nicanor Baltazar as a salesman-in-charge at the Dagupan warehouse of San Miguel Brewery, with an initial monthly salary of P240.00 along with a P5.00 per diem and a commission of P0.075 per case sold. This employment commenced on October 1, 1955. On October 9, 1956, a strike by sixteen regular workers at the Dagupan warehouse ensued, allegedly due to Baltazar’s unfair treatment of the employees. To mitigate the situation, Baltazar was recalled to the company’s Manila office on October 13, 1956, based on recommendations from company officials who validated the employees' grievances.

However, on October 15, 1956, upon his arrival at the Manila office, Baltazar was informed that he would not be returning to Dagupan. Following this, he worked at the main office from October 16 until November 2, 1956, during which he was given no specific duties. From November 3, 1956, to Dec

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Facts:

Appointment and Employment Details

• Baltazar was appointed as salesman-in-charge of San Miguel Brewery, Inc.’s Dagupan warehouse on October 1, 1955.
• His compensation package included a basic monthly pay of P240.00, a per diem of P5.00, and a commission of P0.75 per case sold.

Strike and Reassignment

• On October 9, 1956, sixteen regular workers at the Dagupan warehouse initiated a strike.
• The strike was allegedly caused by the unfair treatment administered by Baltazar.
• In an effort to defuse the tension, the sales supervisor and the industrial relations officer conducted a personal investigation and confirmed the employees’ grievances.
• Consequently, Baltazar was recalled to the Manila office on October 13, 1956 upon recommendation by the concerned officers, in anticipation of settling the labor unrest.

Alteration in Work Assignment and Subsequent Absences

• Immediately upon reporting at the Manila office on October 15, 1956, Baltazar was informed by the sales supervisor that he was not to return to the Dagupan branch.
• From October 16, 1956, to November 2, 1956, he reported at the main office without receiving any specific assignment.
• Beginning November 3, 1956 until December 19, 1956, Baltazar absented himself from work for over a month and a half without obtaining prior authorization or notifying his superiors of his prolonged absence.

Grounds for Dismissal and Subsequent Legal Action

• Based on the existing company policy, which considered ten unexcused absences within a calendar year as sufficient ground for dismissal, and the provisions of the Health, Welfare, and Retirement Plan (requiring certification by the company physician for sick leave to be considered authorized), Baltazar was dismissed for cause.
• The dismissal, effective November 30, 1956, was communicated to him via a letter dated December 31, 1956.
• Baltazar commenced legal action on May 2, 1957 against San Miguel Brewery, Inc., despite the trial court’s finding that his dismissal was justified.

Trial Court Findings and Award

• Even though the trial court dismissed Baltazar's complaint and also dismissed the appellant’s counterclaim for lack of evidence, it nonetheless ordered the appellant to pay:
• One (1) month separation pay.
• The monetary equivalent of six months accumulated sick leave (valued at P240.00 per month).
• These awards were granted notwithstanding the established fact of dismissal for cause.

Appellant’s Grounds for Appeal

• The appellant argued that awarding separation pay was erroneous because Baltazar’s dismissal was for cause.
• The appellant further contended that awarding cash equivalent for the accumulated sick leave was in error since:
• The sick leave benefit under the company’s plan required certification by the company physician—a condition not met by Baltazar.
• The benefits were non-commutable and thus not subject to conversion into cash.

Issue:

• Whether the trial court erred in awarding separation pay to Baltazar given that his dismissal was adjudged as being for cause.
• Whether the trial court erred in ordering the payment of the cash equivalent for six months of accumulated sick leave despite the explicit requirement for certification and the non-commutative nature of such benefits as provided in the company’s policy.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)