G.R. No. L-65189 - People vs. Duhan

On September 10, 1987, the Union of Filipro Employees, of which petitioner Benito D. Chua was a member, declared a strike against Nestle Philippines, Inc.
During the strike, several striking employees engaged in violent acts; specifically, they threw stones at the trucks entering and leaving the company premises.
One incident involved a truck whose driver was rendered unconscious by a stone, leading the truck to ram a private vehicle and crash into a beauty parlor, which resulted in the death of three persons and extensive property damage.
As a consequence of the violence, a criminal complaint for multiple murder and frustrated murder was filed against petitioner and several other employees believed to be involved in the stoning incident.
The criminal complaint, however, was eventually dismissed on the grounds of insufficiency of evidence.

On December 17, 1987, following the strike, the union and its members, including petitioner, offered to return to work.

While most of the striking employees were readmitted to work, sixty-nine union officers and thirty-three union members (including petitioner) were initially excluded.

The union’s counsel subsequently sought the reinstatement of five employees, petitioner's inclusion among them, but the request was denied by Nestle Philippines, Inc.
On February 5, 1988, petitioner received a notice of dismissal from the company for his participation in the illegal strike.
Two days after his dismissal notice, petitioner initiated a complaint for illegal dismissal before the Labor Arbiter.

It found that petitioner was validly dismissed, basing its finding on substantial evidence, notably the testimony of Mr. Maniego, the Personnel Supervisor of the Cabuyao Plant.
The testimony specifically indicated that petitioner actively participated by manning the barricade, an act that prevented proper ingress and egress at the company premises.
The decision highlighted that obstructing free passage is an illegal act frowned upon by law.

Backwages amounting to ₱75,920.00 from the time of dismissal.
Separation pay equivalent to one-half month salary for every year of service, totaling ₱13,376.00.

Petitioner's desire for reinstatement led him to appeal the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC), which in turn affirmed the Labor Arbiter’s ruling regarding both the validity of dismissal and the award of "financial assistance".

He alleged that the NLRC had committed grave abuse of discretion by affirming the award of "financial assistance" to him.
He contended that the evidence on record did not substantiate the NLRC’s findings.

The Court acknowledged the well-established evidence of petitioner’s participation in the illegal and violent strike.

The evidence, particularly Mr. Maniego’s testimony, sufficiently established petitioner’s role in manning the barricade during the strike.
Despite the dismissal of the criminal complaint, the administrative findings regarding petitioner’s misconduct were deemed separately sustainable.

The quantum and weight of evidence required for criminal convictions differ significantly from those sustaining a decision by the Labor Arbiter and the NLRC.
Private respondent’s determinations in the administrative proceedings were not automatically negated by the dismissal of criminal charges.

Whether the petitioner’s dismissal for participating in the illegal strike and undertaking acts that impeded lawful ingress and egress at the employer’s premises was justified.
The determination involved assessing the sufficiency of the evidence, primarily the testimony of Mr. Maniego, establishing petitioner's involvement in activities deemed illegal under the law.

Whether the award of "financial assistance" (backwages and separation pay) rendered by the Labor Arbiter and subsequently affirmed by the NLRC was legally justified.
The petitioner argued that the evidence did not substantiate the award.
The key legal debate centered on whether such financial assistance is permissible when an employee is terminated for serious misconduct, particularly when the misconduct adversely affects the employer’s interests.