Case Digest (G.R. No. 116462)
Facts:
Petitioner Reno Foods, Inc. filed a special civil action under Rule 65 challenging the NLRC decisions of May 30, 1994 and July 21, 1994 in NLRC NCR Case No. 00-06-03336-92, which affirmed Labor Arbiter Numeriano D. Villena’s February 10, 1994 decision ordering the reinstatement without back wages of respondent Noel Cantonjos. Cantonjos alleged he was terminated effective January 3, 1990; petitioner alleged abandonment; Cantonjos filed for illegal dismissal on June 18, 1992, the Labor Arbiter initially dismissed the complaint on December 22, 1992, the NLRC remanded on April 27, 1993, and on remand reversed and ordered reinstatement without back wages.
Issues:
- Did the NLRC and Labor Arbiter commit grave abuse of discretion in finding illegal dismissal rather than abandonment?
- Could petitioner invoke laches or estoppel to bar Cantonjos’ claim filed two years and five months after the alleged dismissal?
- Was Cantonjos entitled to back wages when the Labor Arbiter and the NLRC denied such award?
Ruling:
The Supreme Court dismissed the petition and affirmed the May 30, 1994 NLRC decision. The Court held there was no grave abuse of discretion in finding illegal dismissal and ordering reinstatement without back wages. The Court denied Cantonjos’ claim for back wages as final for lack of timely challenge to the NLRC’s affirmation.
Ratio:
The Court found the NLRC’s and Labor Arbiter’s factual findings supported by substantial evidence, noting the employer bore the burden to prove abandonment and failed to show clear and deliberate intent to desert employment or to produce the required written notice under the employer’s rules. Laches was inapplicable because the action was filed within the four-year prescriptive period of Article 1146 and laches is an equitable doctrine not available before prescription expires. Cantonjos’ claim for back wages became final when he failed to file a motion for reconsideration from the NLRC decision.
Doctrine:
- Findings of quasi-judicial bodies supported by substantial evidence are final and not reviewable for mere factual disputes.
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