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 ...
Case Digest (G.R. No. 102411)
Facts:
Background of the Case
The case originated from a robbery involving a Japanese national, Akira Saikyo, who was a passenger on a Philippine Airlines (PAL) flight bound for Singapore on November 13, 1984. While the aircraft was still at the Manila International Airport, Saikyo's attache case was forcibly opened, and Y500,000.00 and US$400.00 were stolen.
Involvement of Security Guards
Vilma Saludario, a security guard from Lanting Security and Watchman Agency (LSWA), which was contracted by PAL, testified that another security guard, Francis P. Dagui, visited her residence on the same day and left some foreign currency with her. Dagui later retrieved the money. Another LSWA guard, Dumpit, reported seeing Dagui counting dollar bills, which led to an investigation.
Confession and Implication of PAL Employees
Dagui confessed to possessing Y200,000.00, which he claimed was part of his share from the robbery. He implicated several PAL employees, including Dominador Zapanta, Cesar Lopez, Edgardo Ferrer, and Wilfredo Omar, stating that they also received shares of the stolen money. A plan was devised to entrap Dagui, leading to his arrest and the recovery of P8,550.00 from him.
Resignation of Employees
On November 26, 1984, Dagui, Zapanta, Lopez, Ferrer, and Omar signed a joint resignation letter, admitting their involvement in the theft and voluntarily resigning from their positions at PAL. The resignation was accepted on January 12, 1985, with forfeiture of separation benefits and prejudice to future re-employment.
Filing of Complaint
On January 14, 1986, Ferrer and Zapanta filed a complaint with the National Labor Relations Commission (NLRC), alleging that they were coerced into signing the resignation letter and were dismissed without due process. The complaint was dismissed for Lopez and Omar due to lack of interest, but proceeded for Ferrer and Zapanta.
Labor Arbiter and NLRC Decisions
The Labor Arbiter ruled in favor of Ferrer and Zapanta, ordering their reinstatement with backwages and attorney’s fees. The NLRC affirmed this decision, finding that PAL failed to prove the voluntariness of the resignation and did not provide due process.
Issue:
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Ruling:
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Ratio:
Voluntariness of Resignation: The Court found that the resignation was voluntary based on the sworn statements of the employees and the testimony of PAL’s security agent, Amando Garcia, who witnessed the execution of the resignation letter. The Court rejected the claim of coercion, noting that the employees had ample opportunity to contest the resignation but chose not to do so until over a year later.
Due Process: The Court held that PAL complied with due process. The employees were investigated, admitted their involvement in the theft, and voluntarily resigned. The Court also noted that the employees’ union, PALEA, did not pursue an administrative investigation, further supporting the conclusion that the resignation was voluntary.
NLRC’s Grave Abuse of Discretion: The Court found that the NLRC disregarded relevant evidence and engaged in strained reasoning to justify its decision. The Court emphasized that the NLRC’s findings were inconsistent with the facts and the law, warranting the nullification of its decision.