Case Digest (G.R. No. 144907-09)
Facts:
Reynaldo Noblado, et al. v. Prtncesita K. Alfonso, G.R. No. 189229, November 23, 2015, the Supreme Court Third Division, Peralta, J., writing for the Court.The petitioners are thirty-eight (38) former workers (gardeners, landscapers/designers, leadmen, laborers and driver) employed by Prtncesita K. Alfonso who operated as an independent contractor under the business name Cherry Alfonso Plant Nursery and provided landscaping services to Sta. Lucia Realty Development, Inc. The petitioners filed separate complaints in January–February 2001 with the arbitration branch of the NLRC (NCR–North) alleging nonpayment of wages and benefits and illegal dismissal effective January 15, 2001; the complaints were consolidated. Respondent defended that the workers were contractual/project employees assigned to Sta. Lucia, that they deliberately stopped work and committed serious misconduct causing Sta. Lucia to cancel the contract, and that some complainants later withdrew their claims.
On March 31, 2003, the Labor Arbiter rendered a decision finding illegal dismissal, ordering reinstatement without loss of seniority and full backwages (computed up to actual reinstatement, which the LA quantified) and awarding P1,497,925.00 (including 13th month and service incentive leave pay and attorney’s fees). Respondent appealed to the NLRC. During the pendency of the appeal respondent submitted affidavits of desistance/quitclaims for eleven (11) of the original 38 complainants; the NLRC took judicial notice of those withdrawals.
On January 31, 2007, the NLRC affirmed the Labor Arbiter’s decision and dismissed respondent’s appeal for lack of merit, and on March 28, 2008 denied respondent’s motion for reconsideration. Respondent then elevated the case to the Court of Appeals in CA-G.R. SP No. 104305.
In its May 29, 2009 Decision the Court of Appeals partially granted respondent’s petition, setting aside the award of backwages and instead ordering respondent to pay each petitioner P10,000.00 as nominal damages for failure to comply fully with the notice requirement, while affirming awards of service incentive leave pay and 13th month pay and upholding the validity of the affidavits of desistance/quitclaims of the 11 withdrawing complainants. The CA denied petitioners’ motion for partial reconsideration by Resolution dated August 18, 2009....(Subscriber-Only)
Issues:
- Are the affidavits of desistance and quitclaims executed by 11 of the 38 original complainants valid and binding?
- Were petitioners illegally dismissed — i.e., did respondent prove a just cause (gross and habitual neglect of duties) under Article 282 of the Labor Code?
- Did respondent observe procedural due process in effecting the dismissals (the two‑written‑notice/hearing requirement)?
- What is the appropriate remedy if dismissal is illegal (reinstat...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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