Title
Cebu Royal Plant vs. Deputy Minister of Labor
Case
G.R. No. L-58639
Decision Date
Aug 12, 1987
Ramon Pilones, dismissed for alleged tuberculosis, was deemed a permanent employee as he worked beyond probation. SC ruled dismissal unjustified due to lack of medical certification and prior clearance violation, ordering reinstatement with limited back wages.

Case Digest (G.R. No. L-58639)
Expanded Legal Reasoning Model

Facts:

  • Employment and Dismissal: Ramon Pilones, the private respondent, was employed by Cebu Royal Plant (San Miguel Corporation). He was dismissed on August 21, 1978, allegedly due to "pulmonary tuberculosis minimal."
  • Probationary Period: The petitioner claimed that Pilones was still on probation at the time of his dismissal, having been employed on February 16, 1978, for a six-month probationary period ending on August 17, 1978.
  • Medical Examination: The petitioner conducted a medical examination on August 17, 1978, which revealed Pilones' condition. The results were not immediately available, and the dismissal occurred four days later.
  • Earlier Employment: Pilones claimed he was first hired in 1977, supported by a 1977 withholding tax statement issued by the petitioner.
  • Clearance Requirement: The petitioner filed for clearance to terminate Pilones' employment on August 28, 1978, seven days after his dismissal.
  • Labor Complaint: Pilones filed a complaint with the Ministry of Labor. The regional director dismissed the complaint, but the Deputy Minister of Labor reversed the decision, ordering reinstatement and back wages.

Issues:

  • Whether Ramon Pilones was a probationary or permanent employee at the time of his dismissal.
  • Whether the dismissal was justified based on the alleged medical condition.
  • Whether the petitioner complied with the legal requirement of obtaining prior clearance for termination.
  • Whether the public respondent (Deputy Minister of Labor) committed grave abuse of discretion in ordering reinstatement and back wages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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