Case Digest (G.R. No. 118506)
Facts:
In Norma Mabeza v. NLRC and Peter Ng/Hotel Supreme, petitioner Norma Mabeza was employed by respondent Peter Ng initially at the Belfront Hotel and later transferred to Hotel Supreme in Baguio City. Around the first week of May 1991, management required Mabeza and her co‐employees to execute a Joint Affidavit affirming compliance with minimum wage and other labor standards. Mabeza signed the affidavit but refused to swear before the City Prosecutor, upon management’s instruction. That same day, she was ordered to vacate her living quarters and remove her belongings. When she attempted to secure a leave of absence and later to resume work on May 10, 1991, her requests were refused and she was told not to report. On May 13, 1991, Mabeza filed a complaint for illegal dismissal and unpaid benefits before the Labor Arbiter, who, in May 1993, dismissed her case on the ground of loss of confidence supported by a belated criminal complaint for qualified theft. The National Labor Relatio...Case Digest (G.R. No. 118506)
Facts:
- Employment and Joint Affidavit
- Petitioner Norma Mabeza was employed by Peter Ng, first at the Belfront Hotel and later at the Hotel Supreme in Baguio City.
- In early May 1991, management required eight employees, including petitioner, to sign a “Joint Affidavit” attesting to compliance with minimum‐wage and labor‐standards laws.
- Refusal to Swear and Management’s Reaction
- Petitioner signed the affidavit but refused to appear before the City Prosecutor to swear to its contents; management nevertheless submitted it to the DOLE Regional Office on May 7, 1991.
- That same day, petitioner was ordered to surrender her lodging keys, remove her belongings, and was denied an informal leave of absence; on May 10, 1991, she was barred from returning to work.
- Filing of Complaint for Illegal Dismissal and Money Claims
- On May 13, 1991, petitioner filed a complaint before the NLRC–CAR Arbitration Branch (NLRC Case No. RAB‐CAR‐05‐0198‐91), alleging illegal dismissal and underpayment of wages, holiday pay, service incentive leave pay, 13th‐month pay, night differential and other benefits.
- She prayed for reinstatement, backwages and payment of all statutory benefits.
- Private Respondent’s Defenses and Counterclaims
- Initially, Peter Ng alleged that petitioner “abandoned” her job and that alleged monetary claims were settled in kind (meals, lodging, electric and water consumption).
- Eleven months later, he raised loss of confidence, supported by a qualified‐theft complaint filed against petitioner on July 4, 1991, for allegedly stealing hotel property.
- Labor Arbiter and NLRC Resolutions
- On May 14, 1993, Labor Arbiter Felipe P. Pati dismissed petitioner’s complaint, finding serious misconduct (theft of a blanket, bedsheet, towels) as just cause for dismissal.
- On April 28, 1994, the NLRC affirmed the Arbiter’s decision by Resolution, prompting petitioner’s certiorari petition before the Supreme Court.
Issues:
- Whether petitioner’s dismissal was for just cause (abandonment and loss of confidence) under the Labor Code.
- Whether the termination constituted an unfair labor practice by coercing employees to attest to management compliance.
- Whether petitioner is entitled to deficiency wages and benefits, separation pay, backwages and other monetary awards.
- Whether part of petitioner’s money claims are barred by prescription.
- Whether due process (notice and hearing) was observed in petitioner’s dismissal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)