G.R. No. 182499 - Faeldonia vs. Tong Yak Groceries

Petitioner Concepcion Faeldonia was employed by Tong Yak Groceries as a sales/stock clerk from March 1978 until her dismissal on April 20, 2000.
On January 26, 2000, while on an errand for her employer, she stepped on a rusted half-inch nail which injured her foot.
Following the injury, respondent Jayme Go directed her to see Dr. William Ty, who administered antibiotics and pain killers.
Despite two weeks of medication, her condition worsened, leading to further treatment at Metropolitan Hospital in Sta. Cruz, Manila.
At the hospital, she was also diagnosed as diabetic, underwent an operation on her foot, and was confined for 24 days.
The respondents paid the hospital bill amounting to P22,266.40 and later covered other medical and dressing expenses, amounting to almost P70,000.00.

On March 10, 2000, petitioner was summoned by respondent Merlita Go who stated derogatorily that “ayaw na namin sa iyo dahil may sakit ka…” implying her health condition as a basis for dismissal.
Petitioner secured a SSS Sickness Notification signed by Dr. Ty certifying her fitness to resume work on April 20, 2000.
When she reported back on April 20, 2000, she was told to resign with an offer of a sum of money to start a business.
When petitioner inquired about the financial assistance, respondent Merlita Go remarked angrily regarding expenses already incurred.
Thereafter, respondents refused to allow petitioner to resume her work.

Petitioner filed a complaint for illegal dismissal with money claims before the NLRC, contending her dismissal was both without just cause and without due process.
The Labor Arbiter, in its decision on October 29, 2001, found that petitioner was not dismissed from work but, considering her long service, awarded her separation pay and other monetary benefits.
The NLRC reversed the Labor Arbiter’s decision, declaring petitioner was illegally dismissed, ordering her reinstatement without loss of seniority, and directing payment of full back wages and other benefits.
The respondents challenged the NLRC decision by filing a petition for certiorari before the Court of Appeals, which reversed the NLRC finding and reinstated the Labor Arbiter’s ruling.
Petitioner then elevated the case, arguing that the appellate court erred in its reversal, particularly by failing to properly consider the medical certificate supporting her claim that she was fit to return to work.

The medical certificate issued by the company physician attesting her fitness to work clearly supports that she presented herself for work but was refused.
The NLRC’s findings, based on substantial evidence, should prevail over those of the Labor Arbiter.

Only questions of law are permissible in a petition for review on certiorari under Rule 45.
The factual findings of the Labor Arbiter, supported by substantial evidence, should be accorded finality and respect.

The main factual debate centered on whether petitioner abandoned her job or was, in fact, illegally dismissed.

Determination of the true nature of petitioner’s absence from work: Was it abandonment or justified non-attendance due to her injury?

Whether the evidence, including the medical certificate, sufficiently establishes that petitioner was fit to resume work.

Examination of the conflict between petitioner’s submission of a fitness certificate and the respondents’ allegation of her demanding separation pay for health reasons.

Whether the respondents complied with the procedural due process requirements in effecting petitioner’s dismissal.

Analysis of whether proper notice and communications were served to petitioner regarding her dismissal.

The extent to which the findings of labor officials (Labor Arbiter and NLRC) on issues involving abandonment and dismissal should be given deference.