Case Digest (G.R. No. 127718)
Facts:
National Federation of Labor et al. v. National Labor Relations Commission (5th Division), G.R. No. 127718, March 02, 2000, Supreme Court Second Division, De Leon, Jr., J., writing for the Court. Petitioners are members of the National Federation of Labor (NFL) who were employed at the Patalon Coconut Estate, owned/managed by private respondents Susie Galle Reith and Charlie Reith. The estate engaged in agriculture and livestock on a 354-hectare parcel in Patalon, Zamboanga City.In 1988, Congress enacted R.A. No. 6657 (Comprehensive Agrarian Reform Law, CARL) under the Comprehensive Agrarian Reform Program (CARP). Pursuant to CARP, a large portion of the Patalon Coconut Estate was awarded to the Patalon Estate Agrarian Reform Association (PEARA), a DAR‑accredited cooperative of which petitioners are members and agrarian lot beneficiaries. The cooperative took over the estate on August 1, 1994; petitioners’ employment was terminated on July 31, 1994 and they received no separation pay.
On April 25, 1995, petitioners filed individual complaints with the Regional Arbitration Branch (RAB) of the NLRC in Zamboanga City, alleging illegal dismissal and seeking reinstatement with backwages; they were represented by the NFL. On December 12, 1995 the RAB dismissed the illegal‑dismissal charge for lack of merit but ordered respondents to pay separation pay (and certain 13th‑month differentials) to the employees in specified amounts totaling P586,774.22.
Private respondents appealed to the NLRC (5th Division). On April 24, 1996 the NLRC modified the RAB decision: it held respondents not guilty of illegal dismissal because the cessation of operations was involuntary and resulted from state action (CARP), and therefore the employees were not entitled to separation pay; it set aside awards of 13th‑month differentials except as to computation based o...(Subscriber-Only)
Issues:
- Is an employer compelled to cease operations because of compulsory government acquisition of its land under R.A. No. 6657 (CARL) liable to pay separation pay to affected employees under Article 283 of ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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