G.R. No. 122876 - Cheniver Deco Print Technics Corp. vs. National Labor Relations Commission

Case Digest (G.R. No. 122876)
Expanded Legal Reasoning Model

Facts:

Parties and Background

Petitioner: Cheniver Deco Print Technics Corporation, a duly organized corporation operating a printing business in Makati.
Private Respondents:

CFW-Magkakaisang Lakas ng mga Manggagawa sa Cheniver Deco Print Technics Corporation – a registered labor union affiliated with the Confederation of Free Workers (CFW).
Edgardo Viguesilla and twenty-two (22) other individuals, members of the union and former employees of petitioner.

Public Respondent: The National Labor Relations Commission (NLRC), Second Division, which rendered resolutions pertinent to the case.

Notice of Transfer and Relocation

On June 5, 1992, petitioner informed its workers of its decision to transfer operations from Makati to Sto. Tomas, Batangas.
The transfer was necessitated by:

The expiration of the lease contract on the Makati premises.
Refusal by the lessor to renew the lease.
Action by local authorities citing alleged hazards posed by the plant to nearby residents.

Petitioner's implementation measures:

A deadline was given—up to the end of June 1992—for employees to indicate if they would accompany the relocation, failing which replacements would be hired.
A follow-up reminder (June 27, 1992) detailed the schedule:

June 29, 1992 – last day of operations in Makati.

ii. July 1-31, 1992 – temporary shutdown to facilitate the transfer. iii. August 1, 1992 – commencement of operations at the new site in Sto. Tomas.

On August 4, 1992, petitioner issued another communication requiring employees to report to the new location within seven days, with the warning that failure to do so would be deemed as forfeiting their employment.

Employees’ Responses and Subsequent Developments

Following the union’s notification that its members were unwilling to relocate, petitioner granted additional time for reporting to the new site.
Ultimately, despite the union later asserting that the employees had decided to continue working for petitioner, not a single worker reported at the new site.
A group of employees chose instead to accept financial assistance offered by petitioner, while the remaining employees (private respondents) filed a complaint against petitioner alleging:

Unfair labor practice
Illegal dismissal
Underpayment of wages
Non-payment of legal holiday pay
Non-payment of 13th month pay
Non-payment of incentive leave pay
Non-payment of separation pay

Labor Arbitral Proceedings and Awards

On October 27, 1994, the labor arbiter rendered a decision:

Validating the transfer of petitioner's operation as a closure or cessation in Makati.
Acquitting petitioner of unfair labor practice and illegal dismissal.
Directing petitioner to pay:

Separation pay to individual complainants with specified amounts per employee (totaling P422,188.00).

ii. Other money claims amounting to P280,010.00 distributed accordingly among complainants. iii. Attorney’s fees, which were subsequently deleted on appeal due to lack of legal and factual basis.

The NLRC on appeal affirmed the labor arbiter’s decision with the modification of deleting the award for attorney’s fees.

Petition for Certiorari and Petitioner’s Arguments

Petition filed by petitioner alleging grave abuse of discretion by the NLRC.
Main contentions of petitioner:

The transfer of its business did not amount to a closure or retrenchment, and, therefore, the awarding of separation pay was unwarranted.
Private respondents were not terminated but had resigned due to the new work site being too remote from their residences.
Allegations of forum shopping by private respondents based on the filing of separate complaints in other cases.
Claim that some monetary benefits had already been released in connection with a previous enforcement order (pertaining to a wage increase under the Wage Order No. NCR-02).

Court’s Factual Analysis

The Court found that:

The relocation, though justified by the expiration of the lease and external pressures, resulted in the cessation of operations in Makati.
The cessation, even if partial, qualifies as a closure within the meaning of Article 283 of the Labor Code.
The circumstances under which employees did not report to the new site indicate that the separation was not purely voluntary.
The separate cases cited by petitioner concerning different issues and remedies do not amount to forum shopping given their distinct causes of action.

Issues:

Whether the transfer of petitioner’s operations from Makati to Batangas constitutes a closure or cessation of operation that entitles the employees to separation pay.
Whether the employees’ failure to report to the new location should be construed as a voluntary resignation or as an untimely separation attributable to the transfer.
Whether petitioner’s allegations of grave abuse of discretion on the part of the NLRC in upholding the department awards have merit.
Whether the separate cases involving claims of wage underpayment, legal holiday pay, service incentive leave pay, and 13th month pay, as well as claims by individual employees, amount to an act of forum shopping.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 122876) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 122876) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 122876)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 122876)
Expanded Legal Reasoning Model