Case Digest (G.R. No. 167727)
Facts:
Crayons Processing, Inc. v. Felipe Pula, G.R. No. 167727, July 30, 2007, Supreme Court Second Division, Tinga, J., writing for the Court.Petitioner Crayons Processing, Inc. employed respondent Felipe Pula as a Preparation Machine Operator beginning June 1993. On 27 November 1999 Pula suffered a heart attack and was hospitalized for about a week; his wife notified Crayons of his condition. After discharge his attending physician advised a three-month leave. On 25 February 2000 Pula underwent an angiogram at the Philippine Heart Center under Dr. Recto, who advised a two-week leave and subsequently certified him “fit to work.”
Pula returned to work on 11 April 2000 but, after 13 days, suffered a relapse and was again advised to take one month’s leave. He reported back on 13 June 2000 with a physician’s certification of fitness to work. Pula alleged that he was not given any assignment upon return and that on 20 June 2000 he was asked to resign with an offer of P12,000 as financial assistance; he refused and filed a complaint for illegal dismissal (with claims for damages and statutory benefits) naming Crayons and several corporate officers/related entities.
Before the Labor Arbiter, most respondents failed to participate meaningfully; only Nixon Lee appeared to seek exclusion from the suit. In a Decision dated 20 November 2001, Labor Arbiter Marita V. Padolina found that Pula was illegally dismissed, ordered reinstatement without loss of seniority, awarded backwages, service incentive leave pay, 13th month pay and attorney’s fees, and faulted the respondents for nonparticipation and late, unsubstantiated pleadings.
The National Labor Relations Commission (NLRC), however, reversed in a Decision dated 18 March 2003, holding that Pula had been out of work for more than six months due to his illness and that termination under Article 284 of the Labor Code was therefore valid (though Pula was entitled to separation pay). On appeal by Pula via certiorari to the Court of Appeals, the CA, in a Decision dated 25 October 2004, annulled the NLRC ruling and reinstated the Labor Arbiter: it applied the suppletory rule that material allegations not specifically denied are deemed admitted (Section 11, Rule 8, 1997 Rules of Civil Procedure) and rejected a report by Crayons’ HR head (Ellen Caluag) as hearsay and of no probative value.
Crayons sought review in this Court. It urged that the Court of Appeals erred in dismissing the Caluag report a...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in refusing to give probative value to the Caluag report introduced at the appellate level?
- Was the NLRC correct in ruling that termination of Pula’s employment was valid under Article 284 of the Labor Code absent a prior certification by a competent public health authority that the disease could not...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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