Title
C. Planas Commercial vs. National Labor Relations Commission
Case
G.R. No. 121696
Decision Date
Feb 11, 1999
A deliveryman filed for illegal dismissal and unpaid wages; the Supreme Court ruled in his favor, rejecting claims of abandonment and affirming entitlement to salary differentials, 13th month pay, and leave benefits.
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Case Digest (G.R. No. 121696)

Facts:

Employment and Allegations

  • Ramil de los Reyes was employed by C. Planas Commercial (PLANAS) as a deliveryman starting August 1988. He was later tasked with selling fruits until his alleged dismissal on 4 June 1993.
  • De los Reyes filed a complaint for illegal dismissal and non-payment of basic wages, overtime pay, night shift differentials, 13th month pay, and service incentive leave pay.

Labor Arbiter's Decision

  • On 15 April 1994, the Labor Arbiter ruled in favor of de los Reyes, declaring his dismissal illegal. PLANAS was ordered to reinstate him with back wages and pay salary differentials, 13th month pay, and service incentive leave pay.

NLRC's Reversal

  • The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, finding that de los Reyes had abandoned his job. The NLRC upheld only the award of salary differentials (P36,342.80) but set aside the other monetary claims.

Petitioners' Arguments

  • PLANAS and its manager, Marcial Cohu, argued that de los Reyes was not dismissed but abandoned his job after being confronted about overpricing fruits and pocketing the difference. They also claimed exemption from certain labor benefits, citing their status as a small retail establishment with fewer than 10 employees.

Evidence Presented

  • De los Reyes claimed he worked 14 hours daily without overtime or night shift differentials and was underpaid. He also alleged that PLANAS employed around 30 workers.
  • PLANAS submitted photos showing de los Reyes working at another stall, which they claimed proved abandonment. They denied liability for overtime and other benefits, arguing their business hours were limited and they employed fewer than 10 workers.

Issue:

  1. Whether Ramil de los Reyes was illegally dismissed or voluntarily abandoned his job.
  2. Whether de los Reyes was entitled to his monetary claims, including salary differentials, 13th month pay, and service incentive leave pay.
  3. Whether PLANAS, as a small retail establishment, was exempt from paying certain labor benefits.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court upheld the Labor Arbiter's decision, ruling that de los Reyes was illegally dismissed and entitled to monetary benefits. PLANAS failed to prove its exemption as a small retail establishment and did not provide sufficient evidence to refute de los Reyes' claims.


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