Case Digest (G.R. No. 170122) Core Legal Reasoning Model
Facts:
The case at hand is MCMER Corporation, Inc. et al. vs. National Labor Relations Commission and Feliciano C. Libunao, Jr., under G.R. No. 193421, decided on June 4, 2014. The petitioner, McMer Corporation, Inc., along with its officers Macario D. Roque, Jr. and Cecilia R. Alvestir, contested the rulings made by the Court of Appeals and the National Labor Relations Commission (NLRC) regarding the employment status and treatment of Feliciano C. Libunao, Jr., the private respondent. Libunao was initially employed by McMer as a Legal Assistant on August 5, 1999, and was later promoted to Head of the Legal Department, with an additional responsibility as Officer-in-Charge of the company’s Legal and Administrative Department. His monthly salary amounted to P10,500.00, along with allowances totaling P8,500.00. A strained relationship developed between Libunao and petitioners, particularly after Roque’s public and belittling remarks towards other employees. The situation escalated on Ju
Case Digest (G.R. No. 170122) Expanded Legal Reasoning Model
Facts:
- Employment Details:
- Private respondent Feliciano C. Libunao, Jr. was employed by petitioner McMer Corporation, Inc. (McMer) on August 5, 1999, as a Legal Assistant. He was later promoted to Head of the Legal Department and concurrently as Officer-in-Charge of the Legal and Administrative Department on January 3, 2000, with a monthly salary of P10,500.00 plus allowances.
- Conflict with Management:
- Libunao and petitioners Macario D. Roque, Jr. (General Manager) and Cecilia R. Alvestir (President) had a strained relationship due to disagreements over company policies and procedures.
- On July 10, 2007, Roque accused two employees of inefficient performance, which heightened tensions.
- Incident on July 20, 2007:
- On July 20, 2007, Roque summoned Libunao to his office to discuss administrative matters, including Libunao’s alleged tardiness and absences.
- Libunao, fearing physical harm from Roque, went to Alvestir’s office instead and requested her to intervene. Roque, in a fit of anger, confronted Libunao and ordered him to proceed to his office.
- Libunao, fearing for his safety, left the office and reported the incident to the Valenzuela Police Headquarters. He did not report for work from July 21 to July 30, 2007.
- Memorandum and Complaint:
- On July 30, 2007, McMer issued a memorandum directing Libunao to explain his absence without official leave (AWOL). Libunao responded on August 6, 2007, explaining his actions.
- On August 6, 2007, Libunao filed a complaint for unfair labor practices, constructive illegal dismissal, non-payment of 13th month pay, separation pay, moral and exemplary damages, and attorney’s fees.
- Labor Arbiter’s Decision:
- The Labor Arbiter ruled that there was no constructive dismissal, as Libunao voluntarily stopped reporting for work due to perceived danger. However, Libunao was awarded a proportionate 13th month pay of P10,834.00.
- NLRC’s Decision:
- The NLRC reversed the Labor Arbiter’s decision, finding that Libunao was constructively dismissed. It awarded him full backwages, separation pay, and moral, exemplary, and nominal damages.
- Court of Appeals’ Decision:
- The CA affirmed the NLRC’s decision, ruling that Libunao was constructively dismissed and entitled to the awarded damages.
Issues:
- Whether the Court of Appeals erred in sustaining the NLRC’s finding that Libunao was constructively dismissed.
- Whether the Court of Appeals erred in upholding the NLRC’s monetary award in favor of Libunao.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)