Case Digest (G.R. No. 102411)
Facts:
- The case involves Philippine Airlines, Inc. (PAL) and the National Labor Relations Commission (NLRC), with Edgardo Ferrer and Dominador Zapanta as respondents.
- On November 13, 1984, a robbery occurred on a PAL flight to Singapore, where a Japanese national, Akira Saikyo, reported the theft of Y500,000.00 and US$400.00 from his attache case at the Manila International Airport.
- Security guard Vilma Saludario testified that another guard, Francis P. Dagui, left money with her on the same day, which he later retrieved.
- Dagui was seen counting dollar bills on November 14, 1984, leading to an investigation where he admitted to receiving stolen money from PAL employees, including Zapanta, Lopez, and Ferrer.
- An entrapment operation led to Dagui's arrest after he attempted to bribe a supervisor.
- Dagui implicated Bonifacio Rodriguez, a PAL employee, who had opened the attache case and taken the money.
- On November 26, 1984, Dagui and the implicated employees signed a joint resignation letter, claiming it was voluntary.
- On January 14, 1986, Ferrer and Zapanta filed a complaint with the NLRC, alleging coercion in their resignations and lack of due process in their dismissal.
- The Labor Arbiter ruled in favor of Ferrer and Zapanta on April 25, 1990, ordering their reinstatement and back wages.
- The NLRC affirmed this decision on August 27, 1991, and denied PAL's motion for reconsideration on October 16, 1991.
- PAL subsequently filed a special civil action of certiorari to nullify the NLRC's decision.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the resignation of Ferrer and Zapanta was not voluntary.
- The Court found that PAL failed to provide due process in the dismissal of Ferrer and Zapanta.
- The Court n...(Unlock)
Ratio:
- The Supreme Court determined that Ferrer and Zapanta's resignation was not voluntary due to substantial evidence of coercion.
- The joint nature of the resignation letter raised doubts about its authenticity, as collective resignations under such circumstances were unusual.
- PAL's lack of active participatio...continue reading
Case Digest (G.R. No. 102411)
Facts:
The case revolves around Philippine Airlines, Inc. (PAL) and the National Labor Relations Commission (NLRC), with Edgardo Ferrer and Dominador Zapanta as respondents. The events began on November 13, 1984, when a robbery occurred on a PAL flight bound for Singapore. A Japanese national, Akira Saikyo, reported that his attache case was forcibly opened at the Manila International Airport, resulting in the theft of Y500,000.00 and US$400.00. Vilma Saludario, a security guard from the Lanting Security and Watchman Agency (LSWA), testified that on the same day, another guard, Francis P. Dagui, visited her and left some money with her, which he later retrieved.
On November 14, 1984, Dagui was seen counting dollar bills, which led to an investigation. He admitted to having received a share of the stolen money from PAL employees, including Zapanta, Lopez, and Ferrer. An entrapment operation was conducted, resulting in Dagui's arrest after he attempted to bribe a supervisor to remain silent. During the investigation, Dagui implicated Bonifacio Rodriguez, a PAL employee, who had opened the attache case and taken the money. Subsequently, Dagui and the implicated employees signed a joint resignation letter on November 26, 1984, stating that their resignation was voluntary and without coercion.
However, on January 14, 1986, Ferrer and Zapanta filed a complaint with the NLRC, claiming they were coerced into resigning and dismissed...