Case Digest (G.R. No. 167462)
Facts:
The case is Manly Express Inc. and Siu Eng T. Ching v. Romualdo Payong, Jr., G.R. No. 167462, October 25, 2005, the Supreme Court First Division, Ynares‑Santiago, J., writing for the Court. Petitioners are Manly Express, Inc. and Siu Eng T. Ching; respondent is Romualdo Payong, Jr. (with co-claimants Hercules Balena, Francisca Adsuara and Flor Palisoc appearing in the proceedings below as employees who filed consolidated complaints).Chronologically, Balena and Payong were employees of Manly Express (Balena as tour coordinator/dispatcher; Payong as a welder). Balena asserted he had demanded correct employee benefits and was thereafter told not to report for work if dissatisfied; he filed a complaint for constructive dismissal and various money claims on May 16, 2000. Payong experienced eye problems late 1999, was treated for cataract in January 2000, but was allegedly prevented from returning to work; on August 1, 2000 Manly sent a letter terminating his employment, citing business losses and his partial blindness as reasons. Payong filed a complaint for illegal dismissal with money claims; his case was consolidated with co-claimants Adsuara and Palisoc.
The Labor Arbiter on July 31, 2001 dismissed Balena’s complaint for want of cause of action but ordered Manly to pay Payong, Adsuara and Palisoc specified monetary awards. The National Labor Relations Commission (NLRC) modified the arbiter’s decision by adjusting amounts due various claimants, while otherwise affirming the other findings; motions for reconsideration were denied. Balena and Payong appealed to the Court of Appeals (CA-G.R. SP No. 83800). On November 22, 2004 the Court of Appeals denied the petition insofar as Balena (affirming the NLRC as to him) but granted it as to Payong, declaring his dismissal unlawful and awarding reinstatement or separation pay and backwages. Manly’s motion for partial reconsid...(Pro-only)
Issues:
- Did the Court of Appeals correctly deny the petition insofar as Hercules Balena, by finding his complaint premature and lacking proof of constructive dismissal?
- Was Romualdo Payong, Jr. validly dismissed on the ground of disease under Article 284 of the Labor Code and the Omnibus Rules (Sec. 8, Rule I, Book VI), including complia...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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