Facts:

The case involves Blazer Car Marketing, Inc. and its owner, Freddie Chua, as petitioners, against spouses Tomas T. Bulauan and Analyn A. Briones, the respondents. The events leading to the case began on November 16, 2003, when Briones, employed as a secretary/warehouse clerk since April 29, 1998, reminded Chua to remit their Social Security System (SSS) contributions and to issue her an employee ID card, which she had not received since her hiring. During this interaction, Briones noted a discrepancy in Chua's signature on a certificate of employment issued to her husband, Bulauan, who had been employed as a driver since December 4, 1999. Chua reacted angrily, leading to Briones being barred from work the following day with Chua stating, "Hoy, tanggal ka sa trabaho." Bulauan, who had been rehired on March 24, 2003, also faced dismissal after being confronted by Chua regarding his wife's actions. The couple filed complaints for illegal dismissal, non-payment ...

Facts:

Employment Details

• Respondents, spouses Tomas Bulauan and Analyn Briones, were employees of petitioner Blazer Car Marketing, Inc., owned and managed by Freddie Chua.
  • Analyn Briones: Hired on April 29, 1998, as a secretary/warehouse clerk with a daily wage of P270.00 plus P30.00 ECOLA.
  • Tomas Bulauan: Worked as a driver from December 4, 1999, to May 4, 2002, and was rehired on March 24, 2003, with a daily wage of P280.00 (inclusive of ECOLA).

Incident Leading to Complaints

• On November 16, 2003, Briones reminded Chua to remit their SSS contributions and requested an employee ID card, which she had not received since her employment began in 1998.
• Briones commented on Chua's signature on her ID card, comparing it to a certificate of employment issued to Bulauan. Chua reacted angrily, shouting at her.
• The next day, Briones was barred from work, with Chua stating, "Pa SSS ka pa diyan. Hoy, tanggal ka sa trabaho."
• Bulauan was also barred from work after Chua told him to separate from his wife if he wanted to keep his job.

Allegations

• Respondents claimed their dismissal was due to Chua's suspicion that they reported his illegal activities (manufacturing and selling car parts) to the NBI, which raided the company in 2001.

Petitioners' Defense

• Chua claimed Briones was caught making unauthorized company ID cards for employees and was under investigation. He alleged she voluntarily stopped working to avoid the investigation.
• Bulauan allegedly stopped working after learning his wife was being investigated.

Labor Arbiter and NLRC Decisions

• The Labor Arbiter dismissed the illegal dismissal complaint but ordered payment of prorated 13th month pay.
• The NLRC affirmed the Labor Arbiter's decision.

Court of Appeals (CA) Decision

• The CA reversed the NLRC, ruling that respondents were illegally dismissed and entitled to backwages, separation pay, and other benefits.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Illegal Dismissal vs. Voluntary Resignation:

   • The filing of a complaint for illegal dismissal negates the claim of voluntary resignation or abandonment. Employers must prove just cause for dismissal with substantial evidence.

2. Serious Misconduct:

   • Misconduct must be serious, related to the employee's duties, and show the employee's unfitness to continue working. The act of making ID cards, even if unauthorized, did not meet these criteria.
   • The ID cards bore Chua's signature, suggesting some level of authorization. No material damage or prejudice was caused to the company.

3. Proportionality of Penalty:

   • Dismissal is the severest penalty and should only be imposed if the infraction is grave. A less punitive measure would have sufficed in this case.
   • Employers must exercise their prerogative to dismiss with compassion, considering the employee's livelihood.