Case Digest (G.R. No. 175345)
Facts:
- Baltazar L. Payno was employed as an electrician by Orata Trading, a signboard and billboard advertising company, starting October 21, 1993.
- He was later promoted to senior installer.
- On April 11, 2000, Payno was informed that Orata Trading would cease operations and Orizon Trading Corporation would take over.
- He inquired about his employment status and separation pay but was told no separation pay would be provided as Orizon Trading was merely absorbing Orata Trading.
- Payno was required to sign a new employment contract with Orizon Trading Corporation.
- Disturbed by this, he filed a complaint for separation pay on May 4, 2000, while continuing to work.
- On June 3, 2000, he was informed he could not report for work unless he signed the new contract.
- The general manager offered him P7,000.00 as separation pay, which he rejected.
- He filed an Amended Complaint on June 5, 2000, adding "illegal dismissal" as a cause of action.
- The Labor Arbiter ruled in favor of Payno, stating he was constructively dismissed and entitled to separation pay and back wages.
- The National Labor Relations Commission (NLRC) affirmed this decision with modifications.
- Respondents filed a petition for certiorari with the Court of Appeals, which ruled in favor of the respondents, stating Payno had voluntarily resigned.
- Payno then filed a petition for review on certiorari to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Baltazar L. Payno, finding that he was illegally dismissed.
- The decision of the Court of Appeals was set aside, and the decision of the National Labor Relations Commissio...(Unlock)
Ratio:
- The Supreme Court emphasized that the burden of proof in termination cases lies with the employer to demonstrate the validity of the dismissal.
- Since the respondents claimed Payno resigned, they were required to provide evidence supporting this claim.
- The Court found no evidence indicating Payno's intention to resign; his immediate filing of a complaint for illegal ...continue reading
Case Digest (G.R. No. 175345)
Facts:
The case involves Baltazar L. Payno as the petitioner and Orizon Trading Corporation, Orata Trading, and Flordeliza Legaspi as the respondents. Payno was employed as an electrician by Orata Trading, a single proprietorship engaged in signboard and billboard advertising, starting on October 21, 1993. He was later promoted to senior installer. On April 11, 2000, Payno was informed by the personnel manager that Orata Trading would cease operations and that Orizon Trading Corporation would take over. He inquired about his employment status and separation pay due to the closure, but was told that no separation pay would be provided since Orizon Trading was merely absorbing Orata Trading and retaining all employees without any changes in salary or rank. However, he was required to sign a new employment contract with Orizon Trading Corporation. Disturbed by this arrangement, Payno filed a complaint against Orizon Trading for separation pay on May 4, 2000, while continuing to work there. On June 3, 2000, he was informed that he would not be allowed to report for work unless he signed the new contract. The general manager offered him P7,000.00 as separation pay, which he rejected as insufficient. He subsequently filed an Amended Complaint on June 5, 2000, adding "illegal dismissal" as a cause of action. The respondents admitted Payno's employment history but claimed he intended to resign upon learning that he would not r...