Case Digest (G.R. No. 94279)
Facts:
The case revolves around Rafael G. Palma, the petitioner, and the National Labor Relations Commission (NLRC) along with its respondent, Samahang Magsasaka, Inc. (SMI). Palma had been employed by SMI since 1965 as a meter reader and bill distributor. On January 5, 1984, Palma filed a complaint for illegal dismissal after SMI passed Resolution No. 90-83 on December 20, 1983, which ordered his dismissal for dishonesty due to allegedly connecting illegal jumpers to steal electricity. The dismissal was based on sworn statements from customers who claimed that Palma had placed the jumpers in their homes.
Palma contended that he was denied due process because the sworn statements from the customers were taken only after the resolution for his dismissal had already been passed. The SMI alleged that Palma’s actions constituted serious misconduct, fraud, and willful breach of trust, resulting in significant losses to the company.
A Labor Arbiter ruled in favor of Palma on March 12, 198
Case Digest (G.R. No. 94279)
Facts:
- Employment and Dismissal Context
- Rafael G. Palma had been employed since 1965 as a meter reader and bill distributor for Samahang Magsasaka, Inc. (SMI).
- Palma filed a complaint for illegal dismissal on January 5, 1984, contesting his dismissal allegedly for dishonesty, specifically for connecting jumpers or similar devices to steal electricity.
- Grounds for Dismissal and Company Action
- SMI, through its Resolution No. 90-83 dated December 20, 1983, ordered Palma's dismissal on the ground of dishonesty based on the alleged installation of electric jumpers.
- The resolution was adopted during a board meeting (held on December 20, 1983) with the following key points:
- Resolution passed unanimously by the board members present.
- Explicit directive to dismiss not only Palma but also any employee caught connecting unauthorized electric jumpers.
- The resolution was certified by the Corporate Secretary, ATTY. PACIFICO F. WYCOCO.
- Evidentiary Issues and Due Process Allegations
- Palma contended that his dismissal was precipitated without the observance of due process.
- Sworn customer statements (from Juanito R. Lopez, Cenon Buse, Jr., and Elsie Jardiel) were only taken after the board resolution had been passed.
- Palma argued that the late gathering of evidence compromised his right to a fair opportunity to be heard.
- SMI maintained that the sworn testimonies evidenced Palma’s misconduct, fraud, and willful breach of trust.
- The affidavits aimed at proving Palma’s involvement in the unauthorized electrical connection.
- It was argued that these testimonies, although obtained under questionable impartiality, supported the dismissal decision.
- Procedural History and NLRC Decisions
- Labor Arbiter Decision (March 12, 1985)
- The Labor Arbiter found SMI liable for illegal dismissal.
- Ordered the immediate reinstatement of Palma with full backwages.
- The Arbiter noted that the evidence, particularly the customer affidavits, was insufficient to directly identify Palma as having connected the illegal jumpers.
- Appeal before the NLRC
- SMI’s appeal was initially dismissed by the NLRC Second Division in a Resolution dated February 27, 1986 for being filed late.
- On motion for reconsideration, SMI proved its appeal was filed by mail and was in fact timely, causing the Second Division to vacate its earlier dismissal.
- Subsequent NLRC Decisions
- On August 8, 1986, the Second Division dismissed SMI’s appeal after a review that found no reversible error in the Labor Arbiter’s original decision.
- On January 31, 1990, the Third Division (acting as Commission en banc) rendered a decision setting aside the Labor Arbiter’s ruling and reversing the earlier orders by:
- Upholding the dismissal of Palma as justifiably grounded on serious misconduct and willful breach of trust.
- Petition for Certiorari
- Palma filed a petition for certiorari challenging the Third Division’s decision.
- The main allegation was that the NLRC’s Third Division gravely abused its discretion by treating SMI’s appeal as a motion for reconsideration—a move not permitted by the rules.
- NLRC Rules and Jurisdiction Issues
- The Revised Rules of the NLRC specifically provide that:
- Motions for reconsideration must be filed within 10 calendar days from receipt of the decision.
- Such motions are to be resolved by the division that originally issued the order, resolution, or decision.
- SMI’s “Appeal to the Commission en banc” was, in substance:
- Filed as a motion for reconsideration even though it was a pro forma appeal after the Second Division had already rendered a final and executory decision.
- Filed outside the reglementary period (received on September 9, 1986 and filed on September 22, 1986, when the allowed period had already elapsed).
- The action of the Third Division in entertaining this second motion for reconsideration was contested as an overreach of its jurisdiction, constituting a grave abuse of discretion.
Issues:
- Jurisdiction and Timeliness
- Whether the NLRC Third Division correctly entertained what was essentially a second motion for reconsideration which was:
- Filed outside the prescribed 10-day reglementary period.
- Beyond the one allowable motion for reconsideration as provided by the NLRC rules.
- Whether the motion for reconsideration should have been resolved by the Second Division, the division of origin, as required by the Revised Rules of the NLRC.
- Evidentiary Basis for Dismissal
- Whether the evidence (customer affidavits) was sufficient to establish Palma’s guilt in connecting illegal jumpers.
- Whether the due process requirements were violated by relying on evidence gathered after the dismissal resolution was passed.
- Abuse of Discretion
- Whether the Third Division committed a grave abuse of discretion by:
- Converting an appeal into a motion for reconsideration.
- Exceeding its jurisdiction by resolving a matter that should have been handled by the Second Division.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)