Facts:

The case involves a special civil action for certiorari brought by Lumbia Agricultural and Development Corporation (LADCOR) as the petitioner against the National Labor Relations Commission (NLRC) and respondent Pedro Barrientos Jr. The decision being challenged was rendered by the NLRC on December 9, 1994. The events that led to this case began on January 27, 1992, when nine workers from Hda. Dapdap I, a sugar farm located in Victorias, Negros Occidental, filed a complaint against the owner, Magdalena Fermin, alleging illegal dismissal. The workers stated that they had been employed on the farm since 1977 but were unjustly terminated without notice, simply for refusing to return a 6-hectare lot that had been allocated to them under an earlier amicable settlement stemming from a previous illegal dismissal case.

The complaint also included allegations of unfair labor practices, asserting that Fermin attempted to undermine the National Federation of Sugar Workers Food and General

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Facts:

Background of the Case

• On 19 March 1992, nine (9) workers of Hda. Dapdap I, a sugar farm in Victorias, Negros Occidental, filed a complaint for illegal dismissal against the owner, Magdalena Fermin.
• The workers alleged that after working at the farm since 1977, they were summarily terminated on 27 January 1992 without due notice or valid grounds.

Grounds of Allegation and Underlying Dispute

• The dismissal allegedly resulted from the workers’ refusal to return a 6-hectare lot, which had been allocated to them for cultivation under an “Amicable Settlement” dated 30 September 1986. This settlement was executed to resolve a previous illegal dismissal complaint filed by the workers.
• In addition, the complainants charged Magdalena Fermin with an unfair labor practice, contending that she attempted to break up the National Federation of Sugar Workers Food and General Trades (NFSW-FGT) Union that had forged the said settlement.

Withdrawal and Subsequent Amendment of the Complaint

• On 7 September 1992, eight (8) of the original complainants withdrew from the complaint and resumed work, asserting that their dispute with management had been settled.
• Pedro Barrientos Jr. remained the sole complainant and subsequently amended the complaint on 30 March 1993 by impleading Lumbia Agricultural and Development Corporation (LADCOR)—the real owner of Hda. Dapdap I—as a co-respondent alongside Magdalena Fermin.

Defense Presented by the Respondents

• LADCOR contended that the alleged act of dismissal did not occur on 27 January 1992 as claimed by Pedro Barrientos Jr., but rather, he voluntarily abandoned his work after 1 March 1992 to join an adjacent farm operated by Mr. Ramos.
• LADCOR further argued that it was a separate legal entity from its president, Magdalena Fermin, and thus, she could not be held personally liable for the alleged illegal dismissal.

Rulings of the Labor Arbiter and the National Labor Relations Commission (NLRC)

• Labor Arbiter Merlin D. Deloria ruled in favor of the complainant, finding LADCOR liable for illegal dismissal.
• The ruling noted that LADCOR’s claim of voluntary abandonment was not credible, particularly in view of the complainant’s prompt filing of the illegal dismissal case.
• Although LADCOR was absolved of an unfair labor practice charge, it was nevertheless ordered to pay separation pay (computed as one-month salary for every year of service from 1986), back wages, and attorney’s fees.
• The NLRC later affirmed the Labor Arbiter’s decision in toto, reinforcing that a claim of abandonment is inconsistent with the immediate initiation of an illegal dismissal complaint.

Supreme Court Review and Final Determination

• The petitioner (LADCOR) filed a special civil action for certiorari, challenging the NLRC decision on the grounds of misinterpretation of facts and procedural errors.
• The Supreme Court emphasized that it is not a trier of fact in labor disputes and that the credibility determinations made by the Labor Arbiter and affirmed by the NLRC are binding.
• The Court noted that judicial review in such cases is limited to issues of jurisdiction or grave abuse of discretion, neither of which was demonstrated in the present case.
• Consequently, the Supreme Court dismissed the petition and affirmed the NLRC order, which required LADCOR to pay the complainant back wages, separation pay, and attorney’s fees aggregating to ₱50,107.20.

Issue:

Whether the alleged voluntary abandonment of work claimed by LADCOR could be accepted as a valid defense against the illegal dismissal complaint.

• The issue focused on the credibility of the abandonment argument in light of the complainant’s immediate filing of a dismissal case.

Whether the factual findings made by the Labor Arbiter and later affirmed by the NLRC were binding upon the Supreme Court given the nature of labor disputes.

• This involved determining the proper scope of judicial review in labor cases and the deference owed to lower tribunals’ factual determinations.

• Whether the procedural and substantive requirements under the implementing rules of the Labor Code, particularly regarding the issuance of a notice of dismissal, were adhered to by LADCOR.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)