Case Digest (G.R. No. 200898)
Facts:
Brown Madonna Press, Inc., Thaddeus Anthony A. Cabangon, Fortune Life Insurance Company (now Fortune General Insurance Corporation) and/or Antonio Cabangon Chua v. Maria Rosario M. Casas, G.R. No. 200898, June 15, 2015, Supreme Court Second Division, Brion, J., writing for the Court.Maria Rosario M. Casas was hired in 1984 by a member of the ALC Group and rose to become Vice President for Finance and Administration of Brown Madonna Press, Inc. (BMPI) on December 1, 2003. On January 5, 2007, Casas met with BMPI president Thaddeus Cabangon and Victoria Nava (ALC HR) and was told not to report for work beginning January 8, 2007; Casas contends she was told to stop reporting and was promised separation pay, while BMPI maintains Casas requested a “graceful exit” to avoid an administrative investigation. Casas packed her belongings that day and did not return to work.
BMPI prepared a unilateral “Clearance and Quitclaim” stating Casas would “cease to be connected with the company at the close of office hours on January 16, 2007.” Casas refused to sign it and on May 17, 2007, wrote to Antonio Cabangon Chua asking reconsideration of her termination; BMPI did not respond. On July 20, 2007, Casas filed a complaint for illegal dismissal and related claims before the Regional Arbitration Branch (docketed NLRC LAC 05-001892-08), which resulted in the Labor Arbiter’s decision of February 29, 2008.
The Labor Arbiter (LA) dismissed Casas’s complaint for lack of merit but ordered reinstatement without backwages, concluding that Casas had abandoned her post and that there was no positive and overt act of dismissal (citing Chong Guan Trading Inc. v. NLRC and Security & Credit Investigation, Inc. v. NLRC). On appeal, the National Labor Relations Commission (NLRC) (NLRC NCR Case No. 00-07-07706-07, promulgated July 31, 2009) reversed the LA, finding that BMPI’s unilateral “Clearance and Quitclaim” and BMPI’s failure to act on Casas’s May 17 letter constituted positive and overt acts of dismissal, that due process was not afforded, and that the dismissal was without just cause; the NLRC also held the individual respondents jointly and severally liable.
The Court of Appeals (CA) in CA-G.R. SP No. 116539 (promulgated December 11, 2009) affirmed the NLRC, holding that Casas was presumed innocent until proven guilty, that the two written notices required by the labor rules were not given, and that procedural and substantive due process were violated.
BMPI, Cabangon and Cabangon-Chua filed a petition for review on certiorari under Rule 45 assailing the CA’s affirmation of the NL...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in finding no grave abuse of discretion in the NLRC’s ruling that Casas was illegally dismisse...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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