G.R. No. 172608 - People vs. Mapalo

Petitioners, comprising employees hired as gardeners, landscapers/designers, leadmen, laborers, and drivers, were employed in various capacities by the respondent, operating the “Cherry Alfonso Plant Nursery.”
The respondent, an independent contractor engaged in landscaping and plant nursery operations, claimed that petitioners and their co-employees were hired on a contractual basis in connection with a project for Sta. Lucia Realty Development, Inc.
Petitioners alleged that during their employment they were not paid the salaries, overtime, holiday and premium pay, 13th month pay, and service incentive leave pay to which they were entitled.

Petitioners and other complainants filed separate complaints in January and February 2001 opposing what they argued was an illegal dismissal on January 15, 2001.
The complaints detailed non-payment of benefits, failure to provide due process, and the abrupt termination of employment without prior notice or opportunity to be heard.

At the arbitration stage before the NLRC's National Capital Region-North Sector, the Labor Arbiter rendered a Decision on March 31, 2003, finding the respondent liable for illegal dismissal.

The Labor Arbiter ordered reinstatement with full backwages computed from the date of dismissal and an award for service incentive leave and 13th month pay.

The respondent appealed the Labor Arbiter’s decision with an appeal before the NLRC.

Subsequent decisions by the NLRC (January 31, 2007) affirmed the Labor Arbiter’s ruling and dismissed the appeal.

In further proceedings, the respondent filed a motion for reconsideration which was denied by the NLRC in its Resolution dated March 28, 2008.

The respondent subsequently elevated the case to the Court of Appeals (CA) with their appeal in CA-G.R. SP No. 104305.
In its Decision dated May 29, 2009, the CA partially granted the respondent’s appeal:

The CA set aside the award of full backwages, instead ordering the payment of nominal damages (P10,000 per petitioner) due to the failure to comply with the notice requirement.
The CA, however, affirmed the award for service incentive leave pay and the 13th month pay.

Petitioners filed a Motion for Partial Reconsideration, which was denied by the CA Resolution dated August 18, 2009, prompting the present petition for review on certiorari under Rule 45.

Petitioners contended that they were illegally dismissed without just cause and without due process.

They argued that the CA’s reliance on sample letters (submitted later in the proceedings) and its findings of gross neglect were erroneous.
They asserted that the evidence did not support any deliberate or habitual misconduct warranting dismissal.

Respondent maintained that petitioners, as project-based workers, voluntarily abandoned work and committed serious misconduct leading to the cancellation of her contract with Sta. Lucia.
The validity of the Affidavits of Desistance and accompanying Quitclaims filed by eleven withdrawing complainants was also at issue, with petitioners challenging their propriety.

Whether petitioners were illegally dismissed from employment, given the allegations of non-payment of benefits and the manner of termination.
Whether the respondent complied with the substantive due process requirements by establishing a just or authorized cause for dismissal.
Whether the respondent satisfied the procedural due process requirements including issuance of proper written notices and the opportunity for a hearing prior to termination.
Whether the evidence (including the sample letters and later-submitted documents) sufficiently proves that petitioners committed gross and habitual neglect of duties.
The validity and effect of the Affidavits of Desistance, Quitclaims, and Waivers executed by the withdrawing complainants on the merits of the case.
The appropriate remedial award, particularly the computation of backwages and separation pay in lieu of reinstatement, considering the elapsed time since termination.