Case Digest (G.R. No. 63370)
Facts:
- Petitioner Alejandro Jonas P. Magtoto was employed as a sales administrative clerk at Wyeth-Suaco Laboratories, Inc. since April 18, 1974.
- On September 3, 1980, Magtoto was arrested on rebellion charges and detained for seven months.
- Magtoto informed his employer about his detention and requested to be considered on leave until his release.
- The employer denied his request and gave him five days to secure his release and report for work.
- Magtoto was unable to report for work due to his detention, and the employer considered him resigned as of September 25, 1980.
- The employer filed a report of termination with the Ministry of Labor and Employment.
- Magtoto was released from detention on April 10, 1981, and immediately informed the employer that he would start working again.
- The employer stated that his request to work was still inappropriate as their report of termination was still pending.
- Magtoto filed a complaint against the employer for illegal dismissal.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioner.
- The termination of Magtoto's employment was declared illegal.
- Magtoto was ordered to be re...(Unlock)
Ratio:
The employer's dismissal of Magtoto based on prolonged absence was unjustified because his absence was caused by his detention, which was later found to be without basis.
The employer cannot divorce the detention from the prolonged absence, as one caused the other.
Since the cause for detention, which gave the employer a ground to dismiss Magtoto, proved to be non-existent, the termination was deemed illegal, and reinstatement was warranted.
The employer's argument that Magtoto's unsatisfactory performance and loss of trust and confidence justified his dismissal was rejected.
The employer failed to charge Magtoto with these alleged offenses, give him an opportunity to defend himself, and prove his guilt.
An employee alleged to be guilty of serious offenses must be charged and tried before being dismissed.
The employer did not follow the proper procedures for termination.
The Termination Review Panel, as provided in the collective bargaining agreement, was not convened to review Magtoto's termination.
The employer did not apply for clearance to terminate Magtoto's services as required by the labor regulations.
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Case Digest (G.R. No. 63370)
Facts:
The case of Magtoto v. National Labor Relations Commission involves Alejandro Jonas P. Magtoto, an employee of Wyeth-Suaco Laboratories, Inc. Magtoto had been working for the company since April 18, 1974, as a sales administrative clerk. On September 3, 1980, he was arrested and detained on rebellion charges. He informed his employer about his detention and requested to be considered on leave until his release. However, the company denied his request and gave him five days to secure his release and report for work. When Magtoto failed to do so, the company considered him resigned and terminated his employment on September 25, 1980. Magtoto filed an opposition to the termination, stating that all action should be held in abeyance until his release from military custody. After seven months of detention, the charges against Magtoto were dismissed for lack of evidence, and he was released on April 10, 1981. He immediately informed his employer of his release and expressed his intention to return to work. However, the company stated that his reinstatement was "inappropriate" due to the pending report of termination filed with the Ministry of Labor and Employment.
Issue:
The main issue in the case is whether the seven months of detention by the military authorities, which were later found to be without basis, justified the employer's earlier dismissal of Magtoto.
Ruling:
The Supreme Court ruled in favor of Magtoto, stating that the dismissal was illegal and reinstat...