Title
Bookmedia Press, Inc. vs. Sinajon
Case
G.R. No. 213009
Decision Date
Jul 17, 2019
Employees terminated for leaving work early due to family emergencies; SC ruled dismissal too harsh, awarded separation pay after 22 years.
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Case Digest (G.R. No. 213009)

Facts:

Background of the Parties

  • Petitioners: Bookmedia Press, Inc. (a local printing company) and Benito J. Brizuela (president of Bookmedia).
  • Respondents: Yanly Abenir and Leonardo Sinajon, hired in 1995 and 1996, respectively, as in-house security personnel tasked with securing the safety of Brizuela and monitoring contractual workers.

Incident on July 20, 1997

  • Brizuela received a report from Larry Valdoz, a security guard, alleging that respondents left the company premises shortly after punching in their time cards. Sinajon later returned to punch out both his and Abenir’s time cards.
  • Brizuela summoned respondents for an explanation, but they ignored him initially. The next day, respondents submitted letters explaining their actions:
    • Abenir: Left early due to a family emergency (his brother was in trouble) and forgot to punch out, so he asked someone else to do it.
    • Sinajon: Left early to repair his roof due to an impending storm and care for his sick wife. He returned at 6:00 p.m. and waited for his replacement.

Termination and Complaint

  • On July 22, 1997, Bookmedia terminated respondents, alleging repeated violations of company time policy.
  • Respondents filed a complaint for illegal dismissal, claiming their termination was without cause and due process.

Labor Arbiter (LA) Decision

  • The LA ruled in favor of respondents, finding their dismissal illegal. The LA noted that petitioners failed to prove repeated violations, as the only evidence was the July 20, 1997 incident. The LA deemed the penalty of dismissal too harsh and suggested a written reprimand instead.

Appeals

  • Petitioners appealed to the National Labor Relations Commission (NLRC), but their appeal was initially dismissed for procedural reasons. After a petition for certiorari, the CA reinstated the appeal.
  • The NLRC affirmed the LA’s decision, and the CA upheld the NLRC’s ruling, prompting petitioners to file a petition for review with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Just Causes for Dismissal: Under Article 297 of the Labor Code, serious misconduct, willful disobedience, and fraud require willfulness or wrongful intent. The respondents’ actions, while a violation of company policy, were not motivated by wrongful intent but by family emergencies. Thus, they did not qualify as just causes for dismissal.
  2. Proportionality of Penalty: The penalty of dismissal must be commensurate with the gravity of the offense. A single infraction, especially under mitigating circumstances, does not warrant the ultimate penalty of dismissal.
  3. Reinstatement vs. Separation Pay: Due to the passage of 22 years and the strained relations between the parties, reinstatement was deemed impractical. Separation pay in lieu of reinstatement was awarded, and backwages were to be computed up to the finality of the decision.


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