G.R. No. 194467 - Cuadra vs. San Miguel Corporation

Petitioner, Jose R. Dela Torre, was employed as a security guard by respondent Twinstar Professional Protective Services, Inc. since October 1988.
He was deployed at the Las Haciendas in Tarlac City and received a daily wage of P240.00.

In January 2011, petitioner sought assistance through Mr. Tulfo’s program to complain about the underpayment of his salaries.
On January 24, 2011, Commander Cesario Guhilde directed him to report to the Twinstar office in Quezon City.
Upon reporting the following day, petitioner was informed by an administrative officer that he had been placed on “floating status.”
Petitioner alleged that this floating status lasted more than six (6) months, prompting him to file a complaint on August 23, 2011 for illegal dismissal and underpayment/non-payment of certain salaries and benefits.
On October 18, 2011, he amended his complaint, limiting his cause of action to illegal dismissal and non-payment of separation pay.

Despite several summons for mandatory conferences, Twinstar repeatedly failed to appear.
The parties’ submission of position papers was repeatedly reset (first to December 5, 2011, then to January 11, 2012, and finally to January 30, 2012).
On January 30, 2012, only petitioner appeared to submit his position paper.
On March 19, 2012, the LA ruled that petitioner was constructively dismissed and therefore entitled to backwages and separation pay, directing Twinstar to pay backwages of Php1,186,645.83 and separation pay of Php157,560.00.

Twinstar appealed the LA decision to the NLRC.
Twinstar admitted hiring petitioner and his assignment at Las Haciendas, Luisitas, Tarlac City, while also establishing that petitioner went on absence without leave (AWOL) on or about January 21, 2011.
The respondent claimed that it had sent multiple notices—including an Order to Report for Duty (June 3, 2011), a second notice (June 9, 2011), and a Last & Final Order (June 22, 2011)—and further asserted that alternate modes of communication (text messages and phone calls) were employed to contact petitioner.
Petitioner was alleged to have declined to receive a company letter on June 8, 2011 and manifested his unwillingness to return to work.
On August 16, 2012, the NLRC reversed the LA ruling by granting Twinstar’s appeal, ruling that there was no constructive dismissal.
Although Twinstar failed to observe due process in terminating petitioner, the NLRC denied awarding nominal damages on the ground that a valid Quitclaim and Release executed on March 3, 2012, extinguished petitioner's claims.

Petitioner elevated the case to the CA seeking certiorari.
On September 3, 2015, the CA affirmed the NLRC decision, holding that Twinstar had presented its evidence on appeal without grave abuse of discretion, and that petitioner was not illegally dismissed.
The CA reasoned that the Quitclaim executed by petitioner was valid, thereby precluding the award of nominal damages.
On February 11, 2016, the CA issued a resolution denying petitioner’s motion for reconsideration.

The admittance of evidence by the NLRC on appeal despite Twinstar’s prior failure to submit such evidence before the LA.
The finding that petitioner was not illegally or constructively dismissed.
The denial of nominal damages, based on the purported effect of the Quitclaim.

Whether the Court of Appeals gravely erred in affirming the NLRC’s decision to admit and consider Twinstar’s evidence for the first time on appeal, despite it not being submitted before the Labor Arbiter.

Whether the CA erred in finding that petitioner, Jose R. Dela Torre, was not illegally (constructively) dismissed by Twinstar.

Whether the CA erred in affirming the NLRC decision denying the award of nominal damages on the basis of the allegedly valid Quitclaim and Release executed by petitioner.