G.R. No. 60007 - Baja vs. Macandog

Crayons Processing, Inc. employed Felipe Pula as a Preparation Machine Operator starting in June 1993.
Pula’s health issues began on 27 November 1999 when he suffered a heart attack and was confined to the hospital for about a week.
Upon hospitalization, Pula’s wife duly notified the company of his critical medical condition.

After being discharged, Pula was advised by his attending physician to take a three-month leave of absence for recovery.
On 25 February 2000, Pula underwent an angiogram test at the Philippine Heart Center under Dr. Recto, who recommended a two‐week leave.
Following the procedure, Dr. Recto certified Pula as "fit to work" despite the ongoing concerns regarding his heart condition.

Pula returned to work on 11 April 2000 after receiving a certification of fitness.
Thirteen days later, after complaining of dizziness at the company clinic and being diagnosed with a relapse, he was advised to take an additional one-month leave.
On 13 June 2000, Pula resumed work, armed with a new certification of fitness.
Shortly thereafter, on 20 June 2000, Pula claimed that he was not given any post or assignment and was instead asked to resign, with Crayons offering him financial assistance amounting to ₱12,000.
Pula refused the resignation and instead filed a complaint for illegal dismissal, further claiming unpaid benefits such as holiday premium, five days’ service incentive leave pay, and 13th month pay for 1999.

The complaint was filed against Crayons and several other respondents including Clothman Knitting Corp., Nixon Lee, Paul Lee, Peter Su, and Ellen Caluag.
Except for Nixon Lee (who appeared to claim non-management involvement and intra-corporate issues), most respondents did not appear during preliminary conferences and hearings.
Belatedly, the remaining respondents filed a Position Paper asserting that Pula had not been dismissed but rather offered a less strenuous job, and they prayed that he be ordered to report for work without loss of seniority rights.

On 20 November 2001, Labor Arbiter Marita V. Padolina ruled that Pula was illegally dismissed, ordering his reinstatement without loss of seniority and awarding him backwages, service incentive leave pay, 13th month pay, and attorney’s fees.
The Labor Arbiter criticized Crayons and its co-respondents for failing to participate actively in the proceedings and for submitting a belated, unsubstantiated Position Paper.
In contrast, on 18 March 2003 the NLRC ruled that Pula’s termination was proper on the ground that his heart condition had kept him out of work for more than six months, thereby rendering the certification from a public health authority unnecessary under Article 284 of the Labor Code.

Pula assailed the NLRC decision through a special civil action for certiorari before the Court of Appeals.
On 25 October 2004, the Court of Appeals annulled the NLRC ruling and reinstated the Labor Arbiter’s decision favoring Pula.
The Court of Appeals gave weight to the fact that Crayons did not specifically refute Pula’s allegations that he was not given any assignment upon his return and that he was asked to resign shortly after.
The appellate court applied Section 11, Rule 8 of the 1997 Rules of Civil Procedure, treating un-denied material allegations in the complaint as admitted.
Crayons submitted a report by Ellen Caluag (the HRD Head) to support its version of events; however, the Court of Appeals dismissed the report as hearsay because it was undated, unverified, and not notarized.
Crayons further argued that its referral to company doctor Dr. Ting and the asserted prudence in not assigning work to Pula were justified, and it maintained that even assuming termination occurred on 13 June 2000, the NLRC correctly ruled on the validity of termination under Article 284.

The Supreme Court sided with the Court of Appeals in rejecting the evidentiary value of the Caluag report and confirming that Crayons failed to produce credible evidence to counter Pula’s claims.
The Court emphasized that a valid termination on the ground of disease requires a certificate from a competent public health authority confirming that the disease cannot be cured within six months, a requirement that was not met by Crayons.
Ultimately, the petition was denied, affirming that Pula was illegally dismissed, and ordering the costs against the petitioner.

Whether the dismissal of Pula was illegal due to the absence of a mandatory certification from a competent public health authority that his heart condition was incurable within six months.
Whether Crayons Processing, Inc.’s failure to assign work to Pula upon his return and the offer to accept his resignation constituted an illegal dismissal.
Whether the belated filing of a Position Paper and the non-appearance of most respondents affected the adjudication of Pula’s claims.
The admissibility and probative value of the Caluag report submitted by Crayons as evidence to support its version of events.
Whether Crayons’ alleged exercise of prudence and the actions of its former counsel could justify the dismissal under the provisions of Article 284 of the Labor Code and the implementing rules.