Case Digest (G.R. No. L-53060)
Facts:
The case of Rosario T. Mamerto, et al. v. Hon. Amado G. Inciong, et al. arose from a petition for certiorari filed by the petitioners—Rosario T. Mamerto, Fely Dela Cruz, Herman Villalobos, and several others—against the Hon. Amado G. Inciong, Deputy Minister of Labor, and the Lucky Garments Manufacturing Company. The events took place in 1979 surrounding a complaint for illegal dismissal filed by the petitioners due to alleged union activities that led to unfair labor practices. On May 18, 1979, the Director of the National Capital Region, Francisco L. Estrella, dismissed the complaint against Lucky Garments Manufacturing, asserting that the petitioners' actions constituted an illegal sit-down strike that slowed production. The dismissal order indicated that several complainants had absented themselves without notice during a critical production period, while others were dismissed for failing to meet company standards or for violation of company rules. The case's appell
Case Digest (G.R. No. L-53060)
Facts:
- Background of the Case
- Petitioners – comprised of Rosario T. Mamerto, Felisa Dela Cruz, Herman Villalobos, Baudillo Botona, Juanito Dacanay, Eddie Esteban, Garry Baldimor, Gorgonio Javier, Crisostomo Soberrano, Patricio Basilio, Wilson Garcia, Ramon Rabino, Ramon Ruado, Carlito Velarde, et al. – filed a petition for certiorari seeking to annul and set aside administrative orders issued by public respondents.
- Respondents included public officials from the Ministry of Labor (Deputy Minister Amado G. Inciong and Director Francisco L. Estrella) and the private respondent, Lucky Garments Manufacturing Company.
- Issuance of the Orders
- The first challenged order, issued on May 18, 1979, by Director Francisco L. Estrella, dismissed the petitioners’ complaint for illegal dismissal and granted the private respondent’s application for clearance to terminate certain employees on grounds of infractions.
- The second order, dated February 15, 1980, by Deputy Minister Amado G. Inciong, affirmed the earlier decision, thereby reinforcing the clearance to dismiss.
- Classification and Findings Regarding the Employees
- The order identified 28 complainants and classified them as:
- Sixteen (16) regular employees
- Eight (8) apprentices
- Four (4) domestic helpers
- Specific findings per category:
- Regular employees:
- Twelve complainants were noted to have been absent from work from March 7 to March 13, 1979, in what was described as a concerted act amounting to an illegal sit-down strike and economic sabotage.
- Apprentices:
- Eight apprentices were dismissed for their inability to meet the firm’s training standards.
- Domestic Helpers:
- Four individuals, including Eddie Esteban, Garry Baldimer, Adriano Cuaresma, and Jaime Soberano, were determined to be household helpers, employed by a private individual (Mrs. Rosita Kuo) rather than by the firm.
- The Proceedings and Alleged Denial of Due Process
- During conciliation hearings, both parties were required to submit position papers supported by affidavits and documentary evidence.
- The record shows that the respondent complied by submitting the required position paper within the prescribed deadline.
- Petitioners, however, did not submit the necessary evidence and instead filed a motion to have the case certified for compulsory arbitration – a motion that was denied.
- Petitioners alleged that they were denied the opportunity to be heard and that no position paper was ever demanded from them during the proceedings, asserting a violation of their right to due process.
- The record, including the minutes of the conciliation proceedings dated April 4, 1979, clearly shows that petitioners were instructed to submit their evidence which they ultimately defaulted on.
- Developments Leading to the Appeal
- The factual findings of absenteeism, participation in the illegal strike, and violations of company rules were supported by documentary evidence and witness affidavits.
- On appeal, the administrative findings were reexamined, particularly focusing on whether dismissals were legally justified or amounted to an unfair labor practice tied to union activities.
- The case raised issues regarding the validity of summary proceedings in labor disputes and the adequacy of administrative hearings in ensuring procedural fairness.
Issues:
- Whether the dismissal of the petitioners’ complaint for illegal dismissal – based on the multiple categories of employment (regular employees, apprentices, and domestic helpers) and the alleged infractions – was proper and supported by substantial evidence.
- Whether the actions taken by respondent Estrella, particularly the summary issuance of the clearance to dismiss and the subsequent affirmation by Deputy Minister Inciong, constituted a denial of due process.
- Whether petitioners’ failure to submit the required position papers and supporting evidence during conciliation hearings nullified their claim of being denied an opportunity to be heard.
- Whether the classification of certain complainants as apprentices or domestic helpers, as found in the record, was erroneous or an impermissible exercise of discretion.
- Whether the issues raised, particularly regarding termination due to union activities versus other disciplinary infractions, warranted submission to compulsory arbitration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)