G.R. No. 64190 - Polymedic General Hospital vs. National Labor Relations Commission

Private respondent Ricardo Pasadilla was employed by petitioner Polymedic General Hospital as a janitor since August 1979.
His compensation was a monthly salary of P380.00 plus an allowance.

On August 6, 1981, petitioner filed a clearance application with the Ministry of Labor and Employment (MOLE) to effect Pasadilla’s termination.
The grounds for termination were that Pasadilla was caught twice sleeping on duty and once for abandoning his post.
Concurrently, Pasadilla was placed under preventive suspension.

Private respondent opposed the clearance application by filing a complaint for illegal dismissal.
The clearance application and the illegal dismissal complaint were heard jointly for the first time on December 11, 1981.
At the joint hearing, Pasadilla submitted his position paper, affidavit, and documentary evidence.

Petitioner failed to file its own position paper, and no representative appeared on its behalf during the hearing on the morning of December 18, 1981.
Pasadilla was allowed to present his evidence ex-parte, detailing:

The incident where, on July 30, 1981, his salary was withheld and he was informed that he was subject to termination through instructions to tender his resignation.
The creation and submission of a handwritten resignation paper, which he later refused to retrieve when asked, opting instead to tear it up in the presence of hospital personnel and a security guard.
His denial of having committed any negligence, gross misconduct, or violation of hospital rules—stating that the charge of sleeping on duty was untrue based on his physical position while working.
His record of employment clear of any prior reprimands or suspensions due to similar offenses.

On the afternoon of December 18, 1981, petitioner’s counsel appeared and requested an extension until January 3, 1982 to submit its evidence.
No position paper or evidence was submitted by petitioner up to January 15, 1982.
Consequently, the Labor Arbiter delivered a decision on January 19, 1982 ordering Pasadilla’s reinstatement as janitor with back wages and preservation of his seniority rights and other benefits.

Petitioner appealed the decision of the Labor Arbiter before the NLRC, contending that the evidence presented by Pasadilla was insufficient to prove the alleged offenses and that his testimony was biased and self-serving.
The NLRC, through a resolution dated December 20, 1982, affirmed the decision of the Labor Arbiter.

Petitioner claimed that the NLRC’s affirmation involved a grave abuse of discretion amounting to lack of jurisdiction.
It maintained that the evidence supporting Pasadilla’s misconduct was not substantial enough and criticized the reliance on his clearly self-serving testimony.
Petitioner noted that its own records—allegedly showing Pasadilla’s previous offenses—had not been submitted or introduced as evidence.

The Labor Arbiter’s findings highlighted that the clearance application was defective: it was not properly filed with the Ministry of Labor, as evidenced by the absence of a file number and it being notarized on August 5, 1981, rather than following the proper filing procedure.
It was emphasized that in termination cases the burden of proof lies with the employer to show just cause for dismissal.

The decision referenced Article 280 of the Labor Code regarding security of tenure, stipulating that an employee unjustly dismissed is entitled to reinstatement and back wages.
The factual assessments of both the Labor Arbiter and the NLRC were found to be in full accord with the evidence on record and applicable legal standards.
Ultimately, the petition was dismissed for lack of merit, though Pasadilla was adjusted to receive 50% of the back wages initially set.

Whether Pasadilla’s evidence was substantial and credible in refuting the allegations of misconduct (i.e., sleeping on duty and abandonment of post).
Whether the absence of evidence from petitioner undermines the claim of just cause in termination.

Whether the clearance application was properly filed with the Ministry of Labor and Employment, as required for the termination process.
The impact of the defective clearance application on validating the termination decision.

Whether the decisions rendered by the Labor Arbiter and affirmed by the NLRC correctly applied the principle that the burden of proof lies with the employer in termination cases.
The extent to which procedural lapses on the part of petitioner affected the outcome of the case.

Whether the testimony provided by Pasadilla, though self-serving, could be given full weight compared to the uncorroborated and unsystematic evidence (or lack thereof) presented by petitioner.
Whether the NLRC's decision in affirming the Labor Arbiter’s ruling amounted to a grave abuse of discretion and a lack of jurisdiction.