Facts:
On 14 January 1991,
Charlie A. Aldus was employed by
RDS Trucking (formerly Vill-Trade Trucking) as a trailer driver, receiving wages payable on a per trip basis. His average earnings were
P340.00 per trip or
P6,800.00 monthly at an average of twenty trips per month, and instead of a 13th month pay the company allegedly gave monthly bonuses in varying amounts. On 16 November 1993, while driving a truck with Plate No.
PKK-470 belonging to his employer, the truck’s engine suddenly broke down due to a leak in the radiator, requiring the truck to be towed; during the towing, the towing vehicle stopped upon reaching Ortigas, San Juan, Metro Manila, causing the towed truck to bump its rear and resulting in damage to both the cowl and the engine. Upon reaching the office, Aldus was ordered by
Remigio S. de Silva, General Manager of RDS Trucking, to go home and “just look for another job,” and was immediately followed by a termination letter dated
20 November 1993 terminating his services
effective immediately. The letter cited alleged “past infractions” constituting gross negligence and inefficiency, namely: leaving on a trip in 1992 without a helper contrary to company policy and hitting a house in Canlubang, Laguna, allegedly due to careless driving; exceeding a cargo limit by fifteen metric tons in November 1992, allegedly causing damage to a truck with Plate No.
PCC-876; and causing damage to the truck with Plate No.
PKK-470 requiring total engine replacement. Aldus filed a complaint for illegal dismissal before the NLRC National Capital Region Arbitration Branch on 23 November 1993. After a preliminary conference failed to settle the dispute, the Labor Arbiter required position papers, which both parties submitted, with Aldus likewise claiming underpayment of his 13th month pay. Without a formal hearing, the Labor Arbiter declared the case submitted for decision based on the pleadings. On 7 December 1994, the Labor Arbiter ruled that Aldus’ dismissal was illegal, holding that infractions allegedly committed before 16 November 1993 could no longer justify dismissal because Aldus had already been punished for them, and that for the 16 November 1993 incident Aldus was only negligent in failing to check the truck before taking the trip and overlooking the radiator leak; the Labor Arbiter therefore ordered forfeiture of one month’s salary as a sufficient penalty rather than dismissal. The Labor Arbiter ordered reinstatement (physically or through payroll) and payment of backwages less one month’s penalty, and further awarded attorney’s fees and ordered payment in solidum. RDS Trucking appealed to the NLRC, asserting that Aldus was validly dismissed and that the Labor Arbiter committed grave abuse of discretion by deciding based on pleadings. On 29 June 1995, the NLRC affirmed illegal dismissal but deleted attorney’s fees, ruling that RDS Trucking failed to prove that Aldus deliberately caused damage to the truck and that labor arbiters may decide based on position papers without the technical rules of evidence used by courts. RDS Trucking’s motion for reconsideration was denied on 21 November 1995, prompting the petition. While the case was already submitted for decision, RDS Trucking filed a supplemental pleading alleging that Aldus had been convicted on 5 June 1997 by the Metropolitan Trial Court (MeTC), Pasig City, in a criminal case for malicious mischief based on damage to the employer’s truck; the Court noted, however, that Aldus was acquitted because the MeTC found no direct evidence that he deliberately caused damage, and only held him liable for simple imprudence. The Court ultimately affirmed the finding of illegal dismissal but ordered separation pay in lieu of reinstatement due to strained relations, and modified the computation of backwages to start from
20 November 1993, the date of the termination letter.
Issues:
Whether Aldus was illegally dismissed for lack of a valid cause and due process, and whether the later criminal case outcome affected the labor case.
Ruling:
Ratio:
Doctrine: