Case Digest (G.R. No. 181393)
Facts:
- Grandteq Industrial Steel Products, Inc. and its President, Abelardo M. Gonzales, filed a Petition for Review on Certiorari against Edna Margallo.
- Margallo was employed as a Sales Engineer starting August 3, 1999.
- She availed a car loan program after being named "Salesman of the Year," making a down payment of P201,000.00 for a Toyota Corolla.
- Monthly amortization was P10,302.00, with Margallo responsible for P5,302.00 and Grandteq covering P5,000.00.
- On December 29, 2003, Margallo was accused of moonlighting and placed under preventive suspension.
- Margallo claimed she was following orders from her superiors in response to the accusations.
- In January 2004, she was encouraged to resign with a promise of payment for her commissions and benefits.
- Margallo resigned on January 13, 2004, but later claimed Grandteq did not pay her commissions of P87,508.00 or refund her car loan payments.
- Grandteq sold her car for P550,000.00 after her resignation.
- The Labor Arbiter dismissed her complaint on July 11, 2005, for lack of merit.
- The NLRC modified the Labor Arbiter's decision on October 18, 2006, ordering Grandteq to refund her car loan payments and pay her commissions and attorney's fees.
- The Court of Appeals affirmed the NLRC's decision on January 21, 2008, leading to the current petition by Grandteq and Gonzales.
Issue:
- (Unlock)
Ruling:
- The Court upheld the NLRC's decision, declaring the forfeiture clause in the car loan agreement null and void as it contradicted public policy and morals.
- The Court affirmed Margallo's entitlement to unpaid sales commissions, ruling that the burden of proof was on Grandteq and Gonzales to show that these commissions had been paid.
Ratio:
- The Supreme Court concurred with the lower courts that the forfeiture clause in the car loan agreement was unconscionable and against public policy.
- The Court emphasized that contracts should not exploit employees or infringe upon their rights.
- Margallo had made significant payments towards the car loan, and the company's attempt to retain these payments upon her resignation was deemed unjust enrichment.
- The Court reiterated that in labor disputes, the burden of proof regarding the payment of wages and benefits lies with the employer.
- Since Margallo detailed her claims adequately, it was Grandteq and Gonzales's responsibility to provide evidence of payment, which they failed to do.
- The decision reinforced the protective nature of labor laws in favor of employees, ensuring that agreements undermining employee rights are not upheld.
Case Digest (G.R. No. 181393)
Facts:
The case involves a Petition for Review on Certiorari filed by Grandteq Industrial Steel Products, Inc. and its President, Abelardo M. Gonzales, against Edna Margallo. The events leading to the case began when Margallo was employed as a Sales Engineer by Grandteq on August 3, 1999. As a reward for being named "Salesman of the Year," she availed herself of a car loan program of...