G.R. No. 106161 - Ilocos Sur Electric Cooperative, Inc. vs. National Labor Relations Commission

Engr. Egdon Sabio was employed as the Manager of the Engineering Department at Ilocos Sur Electric Cooperative, Inc. (ISECO) starting in May 1982.
On June 8, 1989, Sabio reported to the ISECO Board of Directors about the excessive expenditures and frequent absences of Acting General Manager Atty. Efren Bautista.
The following day, Bautista asked Sabio to resign or take a vacation leave, threatening termination if he did not comply.
Sabio refused and was subsequently relieved of his duties on June 10, 1989, and dismissed on July 1, 1989, following ISECO's Board Resolution No. 63 s. 1989.
Sabio filed a complaint for illegal suspension and dismissal with the National Labor Relations Commission (NLRC).
The Labor Arbiter ruled in favor of Sabio, ordering his reinstatement and awarding backwages and damages.
ISECO appealed to the NLRC, which dismissed the appeal for being filed out of time.
A writ of execution was issued to enforce the Labor Arbiter's decision.
ISECO then filed a petition for certiorari questioning the NLRC's jurisdiction and the legality of Sabio's dismissal.

The Supreme Court held that Presidential Decree No. 269, as amended by P.D. 1645, which pertains to the National Electrification Administration's (NEA) supervision and control over electric cooperatives, does not grant NEA the authority to hear and decide termination cases of employees in electric cooperatives.
This authority is vested in the Labor Arbiter, as provided under Section 217 of the Labor Code.
The Court noted that the petitioners did not question the jurisdiction of the Labor Arbiter during the proceedings and actively participated in them, thus waiving their right to challenge jurisdiction.
Regarding the legality of Sabio's dismissal, the Court found that the employer's prerogative to dismiss an employee must not be exercised arbitrarily and without just cause.
The Court determined that Bautista acted with ...continue reading