Case Digest (G.R. No. 191281)
Facts:
The case revolves around the petition for review on certiorari involving Best Wear Garments, a sole proprietorship managed by Alex Sitosta, as the petitioner and Adelaida B. De Lemos and Cecile M. Ocubillo as the respondents. De Lemos was hired on October 27, 1993, and Ocubillo on July 12, 1994, as sewers on a piece-rate basis. On May 20, 2004, De Lemos filed a complaint for illegal dismissal with prayers for back wages, accrued benefits, separation pay, service incentive leave pay, and attorney’s fees. Ocubillo followed suit with a similar complaint on June 10, 2004.
Both complainants claimed that they were constructively dismissed due to arbitrary transfers to different operations by Sitosta in August 2003, which resulted in a decrease in their earnings. De Lemos asserted that her transfer was due to her refusal to work overtime past 7:00 p.m., causing her to become indifferent to her work environment post-transfer. Ocubillo cited her excessive absences due to personal healt
Case Digest (G.R. No. 191281)
Facts:
- Parties and Employment Background
- Petitioner: Best Wear Garments, a sole proprietorship represented by its General Manager, Alex Sitosta.
- Respondents:
- Adelaida B. De Lemos, hired on October 27, 1993.
- Cecile M. Ocubillo, hired on July 12, 1994.
- Mode of payment: Both respondents were employed on a piece-rate basis, wherein earnings depended on their output.
- Allegations and Initiation of the Case
- In May and June 2004, respectively, De Lemos and Ocubillo filed complaints for illegal dismissal with claims for:
- Backwages.
- Other accrued benefits.
- Separation pay.
- Service incentive leave pay.
- Attorney’s fees.
- Core allegation: The respondents asserted that their transfer orders (originating in August 2003) by Sitosta amounted to constructive dismissal because:
- The transfers resulted in reduced earnings.
- The new assignments were less conducive to generating comparable income.
- Nature of the Work and Specific Incidents
- De Lemos:
- Was transferred more than once under the claim that her refusal to render overtime work (extended up to 7:00 p.m.) led to successive transfers.
- Alleged that her last salary was withheld by the petitioner.
- Ocubillo:
- Asserted her transfer was triggered by her accumulating excessive absences linked to family health issues and her own sickness.
- Claimed that on occasions she could not work due to the unavailability of machines, affecting her earnings.
- Noted disputes regarding overtime work requirements.
- Petitioner’s Version and Additional Developments
- Best Wear Garments denied terminating employment:
- Maintained that the respondents had voluntarily intimated their intention to resign (De Lemos in February 2004 and Ocubillo in March 2004).
- Stated there was no existing policy providing for separation pay, hence no grounds for the respondents’ claims.
- Employment continuity:
- De Lemos did not report back after March 2004.
- Ocubillo failed to report for work from October 2004 onward.
- Decisions of the Lower Courts
- Labor Arbiter’s Decision (September 5, 2005):
- Declared that the respondents were illegally (constructively) dismissed as they neither resigned nor abandoned their jobs.
- Ordered the payment of separation pay and backwages (subject to computation) while dismissing other claims.
- National Labor Relations Commission (NLRC):
- Reversed the Labor Arbiter’s decision.
- Found no sufficient basis for a claim of constructive dismissal, noting:
- The vague allegation of demotion due to transfer.
- Court of Appeals (CA):
- Reversed the NLRC ruling by granting the petition for certiorari in February 2009.
- Reinstated the Labor Arbiter’s decision (with the modification excluding service incentive leave pay in the monetary award).
- Upheld that the transfer order lacked a valid business reason and was prejudicial to the respondents.
- Directed the respondents to report back to work without the payment of backwages, since there was no actual dismissal.
- Subsequent Motions and Elevation to the Supreme Court:
- Petitioners filed a motion for partial reconsideration, which was denied by the CA.
- Petitioner Best Wear Garments elevated the case to the Supreme Court on certiorari, alleging grave abuse of discretion by the CA.
- Supreme Court’s Context and Procedural Considerations
- Review on certiorari under Rule 45 focused on alleged errors of law, not fact-finding.
- The Supreme Court acknowledged the divergence between NLRC’s and CA’s findings, warranting a careful review of evidence.
- Emphasis was placed on the principle that the exercise of managerial prerogative, including transfers, must be based on valid business reasons and free from bad faith or discriminatory intent.
Issues:
- Whether the transfer orders issued by petitioner Best Wear Garments, which allegedly resulted in reduced earnings, constitute a form of constructive (illegal) dismissal.
- Whether the respondents’ claims for separation pay, backwages, and other benefits are justified in the absence of an actual dismissal.
- Whether the appellate court correctly resolved the conflict between the Labor Arbiter’s findings and the NLRC’s assessment regarding the nature and consequences of the transfers.
- Whether the Supreme Court should review the CA’s findings of fact despite the general rule of deference in cases brought by certiorari from the CA.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)