Case Digest (G.R. No. L-26829) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Continental Micronesia, Inc. (CMI) vs. Joseph Basso, G.R. Nos. 178382-83, decided September 23, 2015, the petitioner, a U.S.‐organized airline licensed to do business in the Philippines, employed respondent Basso, a U.S. citizen residing in the Philippines, as General Manager under a written contract dated February 1, 1991. In November 1992, CMI assumed operations of Continental’s Philippine branch with Basso retaining his position. On December 20, 1995, CMI offered Basso an “as needed basis” consultancy effective February 1 to July 31, 1996, without monetary compensation but with insurance, travel privileges, and a housing‐lease advance of ₱1,140,000. Basso’s counter-proposal and inquiries went unanswered until March 1996, when CMI’s Human Resources notified him of termination effective January 31, 1996, invoking the thirty-day “at will” clause in the 1991 contract and offering severance in lieu of his housing advance. Basso filed a complaint for illegal dismissal in Decembe Case Digest (G.R. No. L-26829) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Employment
- Continental Micronesia, Inc. (CMI), a U.S. corporation licensed in the Philippines.
- Joseph Basso, U.S. citizen residing in the Philippines, hired February 1, 1991 as General Manager under a signed employment contract.
- Reorganization and Consultant Offer
- November 7, 1992: CMI takes over Continental’s Philippine operations; Basso remains General Manager.
- December 20, 1995: CMI offers Basso a consultant role (February 1 to July 31, 1996) with no salary but with insurance coverage, travel privileges, and a ₱1,140,000 housing advance.
- Termination and Pre-Judicial Correspondence
- January 11 & March 14, 1996: Basso inquires about employment status; HR responds that under the “at-will” clause he may be terminated with thirty days’ notice, allegedly served December 20, 1995.
- March 14, 1996: CMI terminates Basso effective January 31, 1996, offering severance pay in lieu of reinstatement.
- Labor Tribunal Proceedings
- December 19, 1996: Basso files illegal dismissal complaint before the Labor Arbiter.
- February 10, 1997: CMI moves to dismiss for lack of jurisdiction (foreign contract, lex loci contractus/celebrationis).
- August 27, 1997: Labor Arbiter grants motion, applies U.S. law.
- September 24, 1999: Labor Arbiter dismisses complaint on merits and jurisdiction (applies lex loci).
- November 28, 2003: NLRC sets aside Labor Arbiter decision; finds jurisdiction (voluntary submission), just cause but procedural due process violated; awards US$5,416.00.
- Court of Appeals and Supreme Court Review
- May 23, 2006 CA Decision: Consolidated CMI and Basso certiorari petitions; denies CMI, grants Basso; declares dismissal illegal; orders separation pay plus full backwages; dismisses moral damages and attorneys’ fees.
- June 19, 2007 CA Resolution: Denies CMI’s reconsideration; partially grants Basso’s on backwages computation.
- September 23, 2015: Supreme Court issues its Decision on Rule 45 petition.
Issues:
- Whether the Court of Appeals exceeded its certiorari jurisdiction by reviewing NLRC’s factual findings instead of limiting inquiry to grave abuse of discretion.
- Whether the Labor Arbiter and the NLRC had jurisdiction over the subject matter and parties.
- Whether Basso was validly dismissed for loss of trust and confidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)