Case Digest (G.R. No. 117221)
Facts:
IBM Philippines, Inc., Virgilio L. Pena, and Victor V. Reyes v. National Labor Relations Commission and Angel D. Israel, G.R. No. 117221, April 13, 1999, the Supreme Court, Mendoza, J., writing for the Court.Petitioner IBM Philippines, Inc. (IBM) is a domestic corporation; petitioners Virgilio L. Pena and Victor V. Reyes were ranking officers of IBM. Private respondent Angel D. Israel began employment with IBM on April 1, 1975 and, over sixteen years, held several marketing and engineering positions, received awards, and represented IBM in seminars domestically and abroad. On February 1, 1990 Israel was assigned to Reyes’s team.
On June 27, 1991 Reyes handed Israel a letter terminating his employment effective July 31, 1991, alleging habitual tardiness and absenteeism. Israel filed a complaint for illegal dismissal with the Arbitration Branch, DOLE on July 18, 1991, contending he was not given an opportunity to be heard and that the dismissal lacked proof. IBM defended with documentary evidence consisting principally of print-outs from its internal computer (telematic) messaging system reflecting admonitions, admonitory messages, reports of security guards’ attendance logs, and communications about client complaints; no signed originals or accompanying certifications authenticating those print-outs were offered.
The labor arbiter, on March 13, 1992, found IBM not guilty of illegal dismissal but, in view of Israel’s long service, awarded separation pay (one-half month’s salary per year). Before the labor arbiter’s decision was released Israel attempted to submit additional evidence—Daily Time Records (DTRs) and payslips—showing no unexcused absences or tardiness for June–August 1990 and no deductions for tardiness. IBM did not produce the original DTRs for the contested period at trial.
Israel appealed to the National Labor Relations Commission (NLRC) which, in a decision dated April 15, 1994 (NLRC NCR Case No. 00-01-04250-91; NLRC CA No. 003134-92), reversed the labor arbiter: it held the computer print-outs insufficient to prove habitual tardiness/absences and found Israel had not been afforded due process; it ordered reinstatement and backwages. A presiding commissioner dissented, finding the documentary print-outs convincing and due process satisfied. IBM’s motion for reconsideration before the NLRC was denied (resolution dated July 20, 1994). IBM then filed the present petiti...(Subscriber-Only)
Issues:
- Did the NLRC commit grave abuse of discretion in finding that the computer print-outs submitted by IBM were inadmissible or lacked probative value?
- Did the NLRC commit grave abuse of discretion in finding that private respondent Israel was not afforded due process and that his dismissal was therefore illegal?
- Was remand to the labor arbiter for a clarificatory or formal hearing required befo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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