Case Digest (G.R. No. 106483) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ernesto L. Callado v. International Rice Research Institute, G.R. No. 106483, decided May 22, 1995, the petitioner was employed as a driver by the International Rice Research Institute (IRRI) in Los Baños from April 11, 1983 to December 14, 1990. On February 11, 1990, while on official duty conveying IRRI personnel to and from the Ninoy Aquino International Airport, he met with an accident. A preliminary probe by the IRRI Human Resource Development Department Manager, formalized in a March 5, 1990 memorandum, charged him with (1) driving under the influence of liquor, (2) serious misconduct for failing to report a battery malfunction that allegedly delayed his return, and (3) gross and habitual neglect of duties. Callado submitted his defenses on March 9, 1990, but IRRI terminated his services by Notice of Termination dated December 7, 1990. On December 19, 1990, he filed before the Labor Arbiter a complaint for illegal dismissal, illegal suspension, indemnity pay, moral and Case Digest (G.R. No. 106483) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Employment
- Ernesto L. Callado was employed as a driver by the International Rice Research Institute (IRRI) from April 11, 1983 to December 14, 1990.
- IRRI is an international organization operating under Philippine law, including P.D. 1620, Article 3, which grants it immunity from penal, civil, and administrative proceedings unless expressly waived by its Director-General.
- Accident and Charges
- On February 11, 1990, Callado, while driving an IRRI vehicle on official duty to Ninoy Aquino International Airport and back, was involved in an accident.
- A preliminary investigation by IRRI’s Human Resource Development Department resulted in a March 5, 1990 memorandum informing petitioner of the findings.
- Callado was formally charged with:
- Driving an IRRI vehicle under the influence of liquor;
- Serious misconduct for failing to report a vehicle battery problem, causing an alleged six-hour overstay in Manila;
- Gross and habitual neglect of duties.
- Administrative and Labor Proceedings
- March 9, 1990: Callado submitted his answer and defenses to the charges.
- December 7, 1990: IRRI issued a Notice of Termination.
- December 19, 1990: Callado filed before the Labor Arbiter a complaint for illegal dismissal, illegal suspension, indemnity pay, moral and exemplary damages, and attorney’s fees.
- January 2, 1991: IRRI’s counsel notified the Labor Arbiter and DOLE Regional Director that IRRI enjoyed immunity under P.D. 1620 and had not waived it.
- August 13, 1991: IRRI issued an internal order stating that “in all cases of termination, respondent IRRI waives its immunity.”
- October 31, 1991: The Labor Arbiter rendered judgment ordering reinstatement and backwages amounting to ₱83,048.75, citing the August 13 waiver order.
- March 20, 1992: The NLRC, finding no valid waiver, set aside the Labor Arbiter’s decision and dismissed Callado’s complaint.
- Callado petitioned the Supreme Court, contending that IRRI had waived immunity under a July 26, 1983 internal memorandum and that he was denied due process and effective remedy.
Issues:
- Did IRRI waive its immunity under P.D. 1620 in this case?
- Does the July 26, 1983 internal “Guidelines” memorandum constitute an express waiver by the Director-General?
- Was Callado denied due process in the disciplinary proceedings?
- Did the lack of referral to the Council of IRRI Employees and Management (CIEM) deprive Callado of an effective remedy?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)