Facts:
Gilda C. Fernandez and Bernadette A. Beltran v. Newfield Staff Solutions, Inc./Arnold Jay Lopez, Jr., G.R. No. 201979, July 10, 2013, First Division, Villarama, Jr., J., writing for the Court.Petitioners Gilda C. Fernandez (Recruitment Manager, hired September 30, 2008 at P50,000 + P6,000 allowance) and Bernadette A. Beltran (probationary Recruitment Specialist, hired October 7, 2008 at P15,000 + P2,000 allowance) entered employment agreements with Newfield Staff Solutions, Inc. The agreements included a six-month performance guarantee exposure to liquidated damages (P45,000) for early departure; Fernandez’s contract also provided a loyalty bonus and life insurance upon six months and Beltran’s a 10% increase upon twelve months. Their contracts required a 45-day written notice to terminate after the guaranteed period and provided for surrender of company equipment and clearance requirements.
On October 17, 2008 Newfield’s general manager, Arnold Jay Lopez, Jr., summoned petitioners and, according to petitioners’ sworn statements, told them “You’re fired … this is your last day” and ordered them to turn over records. Respondents maintain Lopez merely called their attention to unsatisfactory performance and that petitioners thereafter stopped reporting for work. Return-to-work letters dated October 22, 2008 directed petitioners to explain their absence. Petitioners sent demand letters in November 2008 claiming unpaid salaries and reimbursement for mobile expenses and then filed a complaint on December 9, 2008 for illegal dismissal, unpaid wages, moral/exemplary damages and attorneys’ fees.
The Labor Arbiter found petitioners were illegally dismissed, awarded back wages and separation pay, and granted attorney’s fees; it rejected Newfield’s abandonment claim. The National Labor Relations Commission (NLRC), in NLRC LAC No. 11-003163-09 (NLRC NCR-12-17096-08), affirmed the Labor Arbiter but modified the backwages award by limiting back wages to the contractual periods (Fernandez: Sept. 30, 2008–Mar. 30, 2009; Beltran: Oct. 7, 2008–Apr. 7, 2009). The NLRC denied motions for reconsideration on January 25, 2011. Respondents then filed a petition for certiorari under Rule 65 in the Court of Appeals (CA-G.R. SP No. 118766); petitioners did not contest the NLRC decision before the CA.
The Court of Appeals reversed on February 23, 2012 and dismissed the illegal dismissal complaint, holding petitioners had ab...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in reversing the NLRC and dismissing petitioners’ complaint for illegal dismissal?
- Were petitioners illegally dismissed, or did they abandon their employment/pre-terminate their guaran...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)