G.R. No. 192190 - Realda vs. New Age Graphics

Billy M. Realda, the petitioner, was employed as the sole machine operator of New Age Graphics, Inc. (also referred to as Graphics, Inc.).
The petitioner brought this petition for review under Rule 45, challenging prior decisions by the National Labor Relations Commission (NLRC), Labor Arbiter Danna M. Castillon, and the Court of Appeals regarding his dismissal from the company.

Refusal to render overtime work despite clear orders to do so to meet production deadlines.
Habitual tardiness and chronic absenteeism even after prior warnings.
Failure to observe prescribed work standards which led to inefficiency in his work as a machine operator.
Insubordination exemplified by ignoring directives of both the petitioner and his General Manager—such as failing to verify printing colors with the prescribed CMYK guide.

The petitioner’s refusal to do overtime work on May 25–26, 2004, despite a valid need to meet client deadlines for projects like La SalleAo Magazine, PCU-Manila Brochure, and Hijas de Maria souvenir program.
Repeated tardiness recorded in January, February, and May 2004, with evidence from Daily Time Records indicating numerous late entries, some personally written by the petitioner.
Unauthorized absences, including a period from June 15 to July 15, 2004, following a warning on absences without official leave.

Prior to his eventual dismissal, the petitioner had been warned and even suspended for his repeated infractions.
A memorandum was issued requiring him to explain his justifications; however, his failure to submit a proper defense was used to establish his insubordination and willful disobedience.
The notice of dismissal, issued on June 15, 2004, provided only a 24‑hour period for the petitioner to respond, which was later examined for compliance with due process requirements.

Even though substantial causes for dismissal (willful disobedience and inefficiency) were recognized, the procedures used in effecting the dismissal were found lacking:

The petitioner was given an unreasonably short period (24 hours) to respond to the allegations.
The scheduled hearing on the same day further curtailed his ability to effectively prepare a defense or secure legal assistance.

Based on these procedural lapses, the Court of Appeals awarded nominal damages to the petitioner, initially set at PhP5,000.00, later modified to PhP30,000.00 in view of precedents cited.

Whether the petitioner’s refusal to render overtime work, habitual tardiness, chronic absenteeism, inefficiency, and acts of insubordination constituted just causes for dismissal.
Whether the aggregate of these infractions, taken in their totality, justified termination under labor standards and company policies.

Whether the petitioner was afforded a reasonable opportunity to defend himself against the charges, particularly in light of the 24‑hour period given for a response.
Whether the procedural requirements—such as a proper issuance of the notice of dismissal with adequate time for defense—were observed in the termination process.

Whether the award of nominal damages should be confined to PhP5,000.00 due to procedural lapses, or if an increased amount (as supported by prior cases) is more appropriate when an employee’s right to due process is violated.