Case Digest (G.R. No. 204075)
Facts:
Cornworld Breeding Systems Corporation and/or Laureano C. Domingo v. Hon. Court of Appeals and Lucena M. Alvaro‑Ladia, G.R. No. 204075, August 17, 2022, the Supreme Court First Division, Hernando, J., writing for the Court. Petitioners are Cornworld Breeding Systems Corporation (Cornworld) and Laureano C. Domingo; respondent is Lucena M. Alvaro‑Ladia. The case reached the Court by a Petition for Certiorari under Rule 65 (later treated in discussion as a Rule 45 remedy issue).Lucena was hired by Cornworld in August 1982 and rose to become Vice President for Research and Development. After Cornworld’s then‑President Benito M. Domingo suffered a stroke on January 16, 2009, Laureano assumed company management. On January 24, 2009, Laureano summoned a meeting during which he publicly berated and ordered Lucena out of the premises; Lucena alleges she was humiliated and thereafter confined for hypertension and applied for sick leave beginning January 26, 2009.
On February 17, 2009, while Lucena was on leave, the company’s Officer‑in‑Charge issued a memorandum informing employees of a Board Resolution (dated January 22, 2009) appointing Alan Canama as Overseer of all offices under Research and Development. Lucena contended this appointment left her position “floating,” and that her salary and benefits were withheld beginning February 2009; she also asserted threats to her person and that on May 25, 2009 Cornworld sent other employees to represent it at a sector meeting instead of her. On June 23, 2009 Lucena filed a complaint for constructive dismissal.
Petitioners countered that Lucena abandoned her post, failed to attend meetings, delegated her duties, and refused to cooperate with new management; they said the appointment of Canama was merely to ensure continuity and that no replacement for Lucena was effected. Lucena filed three sick‑leave applications (covering January 24 to March 16, 2009) and, after discovering she had been sidelined at the May 25 meeting, filed the illegal dismissal complaint promptly.
The Labor Arbiter dismissed Lucena’s complaint in a Decision dated August 24, 2009. On appeal the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter in a Decision dated March 24, 2010, finding neither abandonment nor constructive dismissal; Lucena’s motion for reconsideration was denied. Lucena then filed a petition under Rule 65 with the Court of Appeals (CA) alleging grave abuse of discretion by the NLRC. The CA, in a February 8, 2012 Decision, granted Lucena’s petition, held she was constructively dismissed, and ordered backwages, separation pay (one month per year of service), and attorney’s fees; the CA denied petitioners’ motion for reconsideration in a July 24, 2012 Resolution.
Petitioners filed the instant Petition for Certiorari under Rule 65 with the Supreme Court on September 28, 2012, praying also for a temporary res...(Pro-only)
Issues:
- Was the Petition properly filed under Rule 65 and within the reglementary period, or should it have been a Rule 45 petition filed timely?
- Did the facts establish that Lucena was constructively dismissed rather than having abandoned her employment?
- Could petitioners validly terminate Lucena for loss of...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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