Case Digest (G.R. No. 157010)
Facts:
Philippine National Bank v. Florence O. Cabansag, G.R. No. 157010, June 21, 2005, Supreme Court Third Division, Panganiban, J., writing for the Court.
The petitioner is Philippine National Bank (PNB); the respondent is Florence O. Cabansag, an employee who worked for PNB’s Singapore branch. Cabansag entered Singapore as a tourist in late 1998, applied for and was offered a temporary appointment as Branch Credit Officer by Ruben C. Tobias, General Manager of PNB Singapore. Her appointment letter provided a three‑month probationary period and specified that termination during probation required one day’s written notice and, upon confirmation, one month’s notice (or pay in lieu). PNB’s president in Manila approved the hire, Cabansag secured an Employment Pass from Singapore’s Ministry of Manpower and, through the Philippine Embassy in Singapore, obtained from the POEA an Overseas Employment Certificate dated March 8, 1999.
During her probation Cabansag’s initial performance report was commended. In mid‑April 1999 she was pressured by branch officers—at Tobias’s behest—to resign, allegedly for cost‑cutting and to make way for a Chinese‑speaking officer; she refused. On April 20, 1999 PNB sent a letter terminating her employment. Cabansag filed a complaint for illegal dismissal before a Labor Arbiter. On January 18, 2000 Labor Arbiter Joel S. Lustrias found PNB guilty of illegal dismissal, ordered reinstatement, awarded backwages and specified monetary claims in Singapore dollars, and granted moral and exemplary damages as well as attorney’s fees.
PNB appealed to the National Labor Relations Commission (NLRC). In a June 29, 2001 Resolution the NLRC affirmed the Labor Arbiter’s decision but reduced moral damages and exemplary damages; it later denied PNB’s motion for reconsideration. PNB filed a Petition for Certiorari with the Court of Appeals (CA) under CA‑GR SP No. 68403; the CA (Tenth Division) dismissed the petition by Decision dated July 16, 2002 and denied reconsideration in a January 29, 2003 Resolution. PNB then elevate...(Pro-only)
Issues:
- Is a petition for review under Rule 45 the proper procedural mode to seek review of the Court of Appeals’ decision affirming an NLRC resolution?
- Did the arbitration branch of the NLRC in the National Capital Region have jurisdiction over Cabansag’s illegal dismissal complaint?
- Was the NLRC arbitration in Quezon City a proper venue for Cabansag’s complaint?
- Was Cabansag illegally dismissed, and is she entitled to reinstatement, backwages, moral a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)