Case Digest (G.R. No. 227718) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lagamay v. Cullinan Group, Inc. (G.R. No. 227718, November 11, 2021), Peter Angelo N. Lagamayo was employed on April 2, 2007 by Cullinan Group, Inc., a jewelry manufacturer, as workshop supervisor earning a P16,100 basic salary plus non-tax benefits, allowances, 13th month pay and leave pay. In early 2011, management discovered gambling, drinking, and gold theft in his workshop and, believing he was negligent or complicit, placed him under preventive suspension on February 8, 2011. A Notice to Explain dated February 11, 2011 charged him with breach of trust, dishonesty and negligence. He denied the accusations in writing but was found guilty at a hearing on March 1, 2011. Instead of outright dismissal, he was offered the option to resign, which he communicated in a March 11, 2011 letter requesting unpaid wages, benefits and separation pay. Having not been reinstated after 30 days, he filed on July 11, 2011 before the Labor Arbiter a Complaint for Illegal Dismissal, backwages Case Digest (G.R. No. 227718) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and Hiring
- Cullinan Group, Inc. (CGI), a jewelry producer, employed Peter Angelo N. Lagamayo on April 2, 2007 as workshop supervisor at P16,100 basic salary, P7,900 non-tax, P500 communication allowance, 13th-month pay, and cash equivalent of unused nine sick and nine vacation leave days.
- Rafael M. Florencio served as CGI’s President; Lagamayo reported directly to company management.
- Alleged Infractions and Disciplinary Proceedings
- In 2011 CGI discovered infractions in Lagamayo’s workshop—gambling, drinking, and theft of minute quantities of gold—resulting in a P533,500.00 loss.
- February 8, 2011: petitioner placed under preventive suspension.
- February 11, 2011: Notice to Explain accused him of breach of trust, dishonesty, improper conduct, and negligence.
- February 18, 2011: petitioner denied charges in writing.
- March 1, 2011: hearing found him guilty; petitioner requested to resign to keep his record clean; CGI agreed but refused separation pay.
- March 11, 2011: petitioner submitted written resignation request, demanding unpaid wages, benefits, and separation pay.
- Labor Complaints and Prior Rulings
- July 11, 2011: petitioner filed Complaint for Illegal Dismissal, backwages, and separation pay in lieu of reinstatement before the Labor Arbiter (LA).
- February 29, 2012: LA dismissed the complaint, finding no illegal dismissal.
- July 31, 2012: NLRC affirmed the dismissal but awarded petitioner P96,000.00 for unpaid wages and benefits from March 11 to July 11, 2011; September 18, 2012: NLRC denied reconsideration.
- Court of Appeals (CA) in CA-G.R. SP No. 127383 denied petitioner’s petition, ruling he was constructively dismissed for a just cause (loss of trust and confidence), and affirmed NLRC’s wage award.
Issues:
- Whether petitioner was constructively dismissed from employment.
- Whether petitioner is entitled to reinstatement and/or separation pay and backwages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)