G.R. No. 199975 - Arriola vs. People

Philippine Rabbit Bus Lines, Inc. (petitioner) hired Edwin A. Bumagat (respondent) in March 1991 as a bus driver assigned to the routes Manila-Laoag and Baguio-Manila.
On July 31, 1997, while on duty, respondent’s bus was hit by a speeding truck along the National Highway in Pozorrubio, Pangasinan.
As a result of the accident, respondent sustained serious physical injuries, underwent several surgeries for over two years, and exhausted his six months of accumulated sick leave credits.

On March 17, 2000, respondent addressed a letter to Natividad Nisce, the then President of petitioner, requesting reinstatement as a bus driver.
The letter was not acted upon, prompting respondent to file a Request for Assistance with the Department of Labor and Employment (DOLE) on June 9, 2000, for reinstatement and/or separation pay.
Subsequent developments included petitioner’s unfulfilled promise to reassign respondent to the Laoag City Terminal and respondent’s renewed Request for Assistance with DOLE when no amicable settlement was reached.

When the dispute remained unresolved, respondent filed a formal Complaint for illegal dismissal and money claims against petitioner.
The Labor Arbiter (LA) initially dismissed the complaint on the ground of prescription, noting that respondent’s request to be reinstated came after a prolonged absence due to his injuries.
On appeal, the National Labor Relations Commission (NLRC) found that respondent’s cause of action had not prescribed and remanded the case back to the LA for further proceedings.

The LA, on August 9, 2006, dismissed the complaint for lack of merit, ruling that there was no factual dismissal since respondent had exhausted his sick leaves and was not formally terminated.
The NLRC, in its Resolution dated May 22, 2013, affirmed the LA’s decision, citing the impracticality of keeping respondent’s job open for nearly three years.
Respondent’s motion for reconsideration before the NLRC was denied on September 30, 2013.
The Court of Appeals (CA) reversed the NLRC ruling in its Decision dated December 28, 2018, holding that:

Respondent was constructively dismissed due to petitioner’s failure to assign him a new work position upon his request for reinstatement.
Respondent did not abandon his work.

Petitioner’s Motion for Reconsideration before the CA was denied in the Resolution dated August 14, 2019.

The petition for review on certiorari was filed, assailing the CA’s modified ruling regarding the illegal dismissal of respondent.
The principal issue revolved around whether respondent was illegally dismissed by petitioner, particularly considering issues of due process and the adequacy of the just cause for termination.

The central inquiry focused on the legality of the dismissal based on both substantial and procedural due process.
The issue also encompassed whether the employer discharged its burden of proving just cause for terminating respondent’s employment, particularly in light of his prolonged absence and medical condition.