Case Digest (G.R. No. 208053)
Facts:
Meatworld International, Inc. v. Dominique A. Hechanova, G.R. No. 208053, October 18, 2017, the Supreme Court First Division, Del Castillo, J., writing for the Court.
On September 6, 2006, petitioner Meatworld International, Inc. (a seller of fresh meat under the brand "Mrs. Garcia's Meats") hired respondent Dominique A. Hechanova as a head butcher; at termination he was assigned to Robinsons Place Manila with a monthly salary of P10,600. On March 2, 2011, respondent filed a Complaint for Illegal Dismissal with a claim for reinstatement and backwages (after initiating a Single-Entry Approach at DOLE-CAMANAVA) alleging that following suspensions in November 2010 he was not reassigned, was scolded on January 13, 2011 and told by the Vice-President (Alcoreza) either to resign or be dismissed, and thereafter effectively prevented from resuming work.
Petitioner maintained respondent failed to report for work, recounted prior suspensions and bans (including an SM Hypermarket memorandum), and asserted that there were no available posts after respondent allegedly arrived late for reassignment. The Labor Arbiter, in a January 10, 2012 decision, found respondent illegally dismissed, awarded backwages and separation pay in lieu of reinstatement, and absolved Alcoreza of individual liability. The National Labor Relations Commission (NLRC) affirmed on March 30, 2012; its denial of reconsideration was resolved June 15, 2012.
Petitioner filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA). The CA dismissed the petition on September 12, 2012 for procedural infirmities — lack of proper proof of service and lack of competent evidence of the authority of the corporate representative (no board resolution) — and, on reconsideration, in a July 3, 2013 resolution reiterated the defect as to proof of authority despite conceding proper service. Petitioner then filed the present Petition for Review on Certiorari under Rule 45, challenging the CA's procedural grounds and urg...(Pro-only)
Issues:
- Did the Court of Appeals properly dismiss petitioners' Rule 65 petition on procedural grounds for lack of competent proof of the corporate signatory’s authority and lack of proof of identity?
- Was respondent Dominique A. Hechanova legally dismissed — i.e., did the facts establish constructive (illegal) dismissal justifying the awards of ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)