Case Digest (G.R. No. 223611)
Facts:
Marcos Antonio Morales, Georgina D. Tribujenia, Cicero A. Cajurao, and Noli A. Dejan v. Central Azucarera de La Carlota, Inc., G.R. No. 223611, October 19, 2022, Supreme Court Second Division, Leonen, SAJ., writing for the Court.Petitioners (former employees) worked as housekeeping, utility maintenance, and cooks in the guest houses inside the compound of Central Azucarera de La Carlota, Inc. (respondent). They were rank-and-file employees who, in 2006, were reclassified as confidential employees and removed from the union. In 2007 respondent announced a downsizing program, offered affected employees early retirement or retrenchment/separation pay, and informed them they might be rehired by a separate cooperative at lower pay. Petitioners refused to accept the offer; one coworker accepted. On September 22, 2007 petitioners could no longer clock in and were effectively separated from employment.
On March 30, 2009 petitioners filed for illegal dismissal, unpaid overtime, moral and exemplary damages, and attorney’s fees before the Regional Arbitration Branch VI (Labor Arbiter) of the NLRC in Bacolod. The Labor Arbiter ordered reinstatement but denied backwages because of delay. The NLRC (Seventh Division) initially modified that ruling and ordered respondent to pay backwages, finding respondent failed to prove redundancy and that procedural notices were not shown to have been received. On reconsideration the NLRC reversed itself and found petitioner dismissals were due to redundancy supported by audited financial statements and management prerogative; it awarded separation pay and nominal damages totalling P253,286.56.
Petitioners filed a Petition for Certiorari under Rule 65 with the Court of Appeals. The Court of Appeals denied the petition, finding no grave abuse of discretion in the NLRC’s Resolution, accepting respondent’s audited financials as proof of business losses, and concluding the abolished guest-house positions were not necessary to the core sugar-milling business; the CA also deleted the NLRC’s award of nominal damages. Petitioners’ motion for reconsideration at the CA was denied. They then filed a Petition for Review on Certiorari under Rule 45 to this Court.
This Court initially denied the Petition on July 27, 2016 for failure to show reversible error, but on motion for reconsideration reinstat...(Subscriber-Only)
Issues:
- Whether respondent validly dismissed petitioners on the ground of redundancy.
- Whether respondent complied with the procedural due process requirements for dismissal due to re...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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