Case Digest (G.R. No. L-57769)
Facts:
Columbia Development Corporation v. Hon. Minister of Labor and Employment, Brenda Tadena, Marilyn Jover, Lilia Francisco, Agnes Abaracoso, Estrelita Balignasay, Rebecca Lorenzo and Antonina Dinglasan, G.R. No. 57769, December 29, 1986, Supreme Court Second Division, Fernan, J., writing for the Court.
On February 4, 1980, petitioner Columbia Development Corporation filed with the Ministry of Labor and Employment, National Capital Region, an application for clearance to terminate the services of 22 employees (out of a workforce of 30) on the ground of serious business reverses and continuous losses; the matter was docketed as Case No. NCR-STF-2-704-80. The seven private respondents (the employees named in the caption) opposed the application by filing complaints for illegal dismissal that were treated as oppositions to the clearance application.
Conciliation failed and the parties filed position papers. On August 7, 1980, Director Francisco L. Estrella of the Bureau of Labor Relations denied petitioner’s application for clearance for lack of clear and convincing proof and ordered immediate reinstatement of the private respondents with full backwages and preservation of seniority and other benefits. Petitioner appealed to the Minister of Labor, who dismissed the appeal on April 13, 1981. Petitioner filed a motion for reconsideration and a supplemental motion in which it first argued that the case involved intricate questions of fact and law and should have been certified to the Executive Labor Arbiter for compulsory arbitration; petitioner also attached an audit report and audited financial statements prepared after the Director’s decision.
On June 11, 1981, the Minister denied the motion for reconsideration. Petitioner then brought the present recourse to the Supreme Court, charging grave abuse of discretion, excess or lack of jurisdiction on (a) the failure to certify the case to the Executive Labor Arbiter; (b) disregard of petitioner’s evidence of business reverses; and (c) the reinstatement order. In the proceedings below, the Director had rejected municipal mayor’s permits and similar documents as insufficient to prove losses, stating that audited financial statements were the proper proof; petitioner explained the late submission of audited statements by the logistical difficulty ...(Subscriber-Only)
Issues:
- Did the Minister of Labor (and the Regional Director) commit grave abuse of discretion by not certifying Case No. NCR-STF-2-704-80 to the Executive Labor Arbiter for compulsory arbitration?
- Did the Minister of Labor commit grave abuse of discretion by disregarding petitioner’s evidence of serious business reverses and ordering reinstatement with backwages?
- Was petitioner legally justified to terminate employment for business reverses, and what remedies...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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