Title
Supreme Court
Mehitabel, Inc. vs. Alcuizar
Case
G.R. No. 228701-02
Decision Date
Dec 13, 2017
A labor dispute involving alleged illegal dismissal of a Purchasing Manager, with claims of abandonment and poor performance, ultimately ruled as abandonment by the Supreme Court.

Case Digest (G.R. No. 228701-02)
Expanded Legal Reasoning Model

Facts:

  • Background of the Parties
    • Petitioner: Mehitabel, Inc., a duly registered corporation engaged in manufacturing high-end furniture for export.
    • Respondent: Jufhel L. Alcuizar, hired on August 31, 2010 as Purchasing Manager in the company’s Purchasing Department, composed of a Purchasing Manager, a Purchasing Officer (handling local purchases), a QC Inspector, and an Expediter.
  • Performance Issues and Initial Incidents
    • During the first few months of his employment, the respondent obtained a satisfactory performance rating.
    • Beginning in March 2011, various complaints on his work ethics and poor performance were received by his immediate supervisor, Rossana J. Arcenas, leading to delays in production and delivery and a growing dissatisfaction among top-level officers.
    • In early August 2011, after repeated counselling by Arcenas regarding his performance, it was alleged that respondent’s work attitude did not improve, raising concerns about his future with the company.
  • Alleged Abandonment and Employer’s Response
    • Arcenas asserted that on August 10, 2011, the respondent left the company premises and verbally indicated that he was quitting his job.
    • The facts were corroborated by Sherrie Mae A. CaAete (Human Resource Officer) and Wilma R. Molina (security personnel), both of whom attested that the respondent informed them of his intention to sever the employer-employee relationship.
    • On the same day, petitioner sent a registered letter to respondent, warning him that his leaving without permission was a violation of the company's code of conduct (abandonment) and directing him to report back to work with a written explanation.
  • Subsequent Developments
    • Despite receiving the warning letter, the respondent neither returned to work nor submitted his explanation.
    • Instead, the respondent filed a labor complaint, alleging illegal dismissal, non-payment of salary, 13th month pay, damages, and attorney’s fees, and prayed for his reinstatement with backwages.
    • The respondent argued that prior publications of a job vacancy (purportedly for the Purchasing Manager position) and confirmation by Arcenas and company president Robert L. Booth indicated that he was dismissed and replaced.
  • Proceedings in Quasi-Judicial Bodies
    • Labor Arbiter’s Decision (January 12, 2012):
      • The Labor Arbiter dismissed the respondent’s complaint for lack of merit, finding insufficient substantial evidence to prove the fact of dismissal.
    • National Labor Relations Commission (NLRC) Decision (July 31, 2012):
      • The NLRC reversed the Labor Arbiter’s ruling by declaring the dismissal as valid for just cause due to the respondent’s poor performance (gross inefficiency) and habitual neglect of duty.
      • Despite establishing a substantive ground for dismissal, the NLRC awarded respondent nominal damages of ₱10,000 for the alleged failure to observe due process.
    • Court of Appeals (CA) Decision (May 19, 2016):
      • The CA partly granted the respondent’s petition by reversing both the earlier July 31, 2012 NLRC decision and the Labor Arbiter’s decision, ruling that the respondent was illegally dismissed.
      • The CA ordered the reinstatement of the respondent with full backwages, reinstatement without loss of seniority rights, and payment of attorney’s fees equivalent to 10% of the monetary award.
    • Petitioner later moved for reconsideration but the CA maintained its ruling, prompting the present petition for review on certiorari.
  • Evidence and Testimonies Pertaining to Abandonment
    • The respondent’s conduct on August 10, 2011, including abandoning the workplace and failing to comply with the Return to Work order sent via registered mail, was reinforced by affidavits from CaAete and Molina.
    • Specific details from the affidavits:
      • CaAete testified that respondent mentioned he was “quitting his job” and had arranged to take his personal belongings.
      • Molina recorded on the exit logbook that the respondent stated he was quitting and was allowed to leave, further evidencing his abandonment.
    • Verification that the publication of the job vacancy was a typographical error, intended to advertise the vacancy for Purchasing Officer, not Purchasing Manager, and that respondent was previously informed of this error.

Issues:

  • Whether there is sufficient evidence to establish the fact of dismissal as alleged by the respondent.
    • Did the respondent’s actions and the surrounding circumstances amount to an employer-initiated dismissal?
    • Is the publication of a job vacancy, amidst an admitted error, enough to prove dismissal?
  • Whether the respondent’s conduct constitutes abandonment of employment.
    • Can the respondent’s failure to return to work after receiving a Return to Work order be interpreted as abandonment?
    • Do the affidavits of company personnel substantiate the claim of abandonment?
  • Whether due process was observed by the petitioner in terminating the respondent’s employment.
    • Did the petitioner provide the necessary procedural safeguards before effecting termination?
    • Is filing a complaint for illegal dismissal sufficient to negate an employee’s abandonment, or must other factors be considered?
  • Whether the application of Article 4 of the Labor Code (ambiguity in evidence weighted in favor of labor) by the CA is proper in light of the evidence.
    • Is the respondent’s evidence more probative than the petitioner’s?
    • Should doubts in interpreting the evidence tilt the balance in favor of the employee in this case?
  • Whether the awarding of attorney’s fees against the petitioner is supported by substantial evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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