Title
Gandara Mill Supply vs. National Labor Relations Commission
Case
G.R. No. 126703
Decision Date
Dec 29, 1998
Employee dismissed after unexcused absence; employer failed to comply with due process. NLRC upheld separation pay, backwages, and attorney’s fees; SC affirmed, citing procedural lapses and compassion for family emergencies.

Case Digest (G.R. No. L-23861)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner Milagros Sy, owner of Gandara Mill Supply, a small business in Binondo, Manila, employed only two workers including Silvestre Germano (the private respondent).
    • The private respondent failed to report to work from February 6 to February 11, 1995, without notifying his employer, to be with his wife who gave birth on February 12, 1995.
    • Petitioner extended some financial assistance to the private respondent during this period.
  • Absence and Suspension
    • The private respondent’s absence, given the small workforce, caused operational difficulties for Gandara Mill Supply.
    • After roughly two weeks, the private respondent returned to find that someone was hired to replace him, with a statement that he could be readmitted only by June 1996.
  • Labor Case and Proceedings
    • On February 27, 1995, the private respondent filed a complaint for illegal dismissal before the Department of Labor and Employment.
    • Petitioner offered P5,000.00 to settle the claim, which the private respondent rejected.
    • The Labor Arbiter set deadlines for submission of position papers by petitioner: April 28, 1995, extended to May 5, 1995, and then again a final extension of 7 days from receipt of May 9, 1995 Order.
    • Petitioner failed to file the position paper despite repeated opportunities, leading to a decision on January 29, 1996 ordering petitioner to pay private respondent P65,685.90 for separation pay, backwages, service incentive leave pay, and attorney’s fees.
  • Appeal and NLRC Resolution
    • Petitioner appealed on March 4, 1996, but failed to post the required cash or surety bond, arguing small business status and requesting exemption or delay.
    • NLRC dismissed the appeal on May 22, 1996, for failure to comply with bond posting requirements.
    • Petitioner’s motion for reconsideration was denied on July 23, 1996.
    • The private respondent filed motions for execution and the NLRC issued a writ of execution on September 13, 1996.

Issues:

  • Whether the NLRC committed grave abuse of discretion in dismissing petitioner’s appeal and not allowing petitioner an opportunity to prove that the private respondent was suspended rather than illegally dismissed.
  • Whether the NLRC committed grave abuse of discretion in awarding the private respondent P65,685.90, an amount petitioner claims is excessive.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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