Case Digest (G.R. No. 69870)
Facts:
National Service Corporation (NASECO) and Arturo L. Perez, petitioners, vs. the Honorable Third Division, National Labor Relations Commission, Ministry of Labor and Employment, Manila and Eugenia C. Credo, respondents, G.R. No. 69870; and Eugenia C. Credo, petitioner, vs. National Labor Relations Commission, National Service Corporation and Arturo L. Perez, respondents, G.R. No. 70295, November 29, 1988, Supreme Court En Banc, Padilla, J., writing for the Court.Eugenia C. Credo was employed by NASECO, a corporation supplying guards and manpower services to the Philippine National Bank, beginning 18 July 1975 and rising to Chief of Property and Records by 10 March 1980. In October 1983 NASECO manager Sisinio Lloren issued a memorandum on entry procedures in the Statement of Billings Adjustment; Credo allegedly failed to comply and allegedly behaved discourteously when confronted. On 7 November 1983 she was called before Acting General Manager Arturo L. Perez and the Committee on Personnel Affairs and, that same day, placed on a 15‑day "Forced Leave" effective 8 November 1983.
While still on forced leave, Credo filed a complaint with the Arbitration Branch, Ministry of Labor, docketed Case No. 11‑4944‑83, on 18 November 1983 alleging forced leave without due process. On 22 November 1983 the Committee on Personnel Affairs deliberated prior incidents and, finding multiple disciplinary infractions, recommended termination with forfeiture of benefits. A Notice of Termination dated 24 November 1983 was in fact handed to Credo on 1 December 1983, effective 1 December 1983. Credo filed a supplemental illegal dismissal complaint on 6 December 1983.
The Labor Arbiter, after receiving position papers and evidence, rendered a decision on 9 May 1984 dismissing Credo's complaint but awarding separation pay equivalent to one‑half month’s pay per year of service. Both parties appealed to the Third Division of the National Labor Relations Commission (NLRC). On 28 November 1984 the NLRC reversed the Labor Arbiter: it ordered NASECO to reinstate Credo to her former or substantially equivalent position with six months' backwages and without loss of seniority, and it dismissed Credo’s claims for attorney’s fees and moral and exemplary damages. Motions for reconsideration were denied by NLRC resolution dated 16 January 1985.
The ...(Pro-only)
Issues:
- Did the NLRC have jurisdiction to entertain and grant reinstatement and related relief against NASECO given its status as a government‑owned or controlled corporation?
- Did the NLRC commit grave abuse of discretion in ordering Credo’s reinstatement and awarding backwages for the period of her separation?
- Was Credo entitled to attorney’s fees, moral and exemplary damages, and a longer period of backwages t...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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