G.R. No. 222816 - Reyes vs. Global Beer Below Zero, Inc.

Petitioner Allan John Uy Reyes was employed as Operations Manager by respondent Global Beer Below Zero, Inc. from January 2009 until January 2012.
On January 18, 2012, in the performance of his duties, Reyes reported to the main office in Makati to request for budget, instead of proceeding to the Pasig warehouse.
On January 19, 2012, Reyes encountered a delay due to the illness of his three-year-old son.

Around 10:30 a.m. on January 19, 2012, Global’s Vice-President for Operations, Vinson Co Say—who was Reyes’ immediate and direct supervisor—called Reyes to inquire why he had not yet arrived at the office.
During the call, after Reyes apologized and attempted to explain his lateness, Co Say shouted instructions, telling Reyes not to report for work anymore; he even stated that he would speak with Reyes the following week before abruptly hanging up.
Following this call, Reyes, acting in accordance with Co Say’s directive, refrained from reporting for work and awaited further instructions.

On January 24, 2012, Reyes received a text message from Co Say inviting him to meet ("Allan, let's meet thu, puno ako today, bukas").
On January 26, 2012, another text message from Co Say set a meeting at Starbucks Waltermart, where Co Say reiterated his instruction that Reyes should no longer report for work and insisted that Reyes file a resignation letter.
Reyes refused to file a resignation letter, contending he had not committed any act warranting dismissal.

Believing that his dismissal was both unjust and constructive, Reyes filed a complaint for constructive dismissal on February 22, 2012, which he later amended to an illegal dismissal case on March 29, 2012.
Respondent Global, on the other hand, contended that Reyes voluntarily ceased reporting for work, noting his repeated violations of company policies.
Global accused Reyes of several infractions, including unauthorized absences, tardiness, filing leave applications only after incurring absences, misuse of vacation leave, overpayment of salary due to unearned leaves, incurring personal expenses on company services, and failure to properly attend to urgent work matters.

The Labor Arbiter ruled in favor of Reyes on November 28, 2012, finding that despite the allegations of misconduct, the evidence pointed more toward a dismissal rather than abandonment.
The Labor Arbiter awarded Reyes full backwages, separation pay, and attorney’s fees, with a computed total judgment award of PhP265,045.00.
The National Labor Relations Commission (NLRC) subsequently affirmed the Labor Arbiter’s decision, emphasizing that Reyes had adequately stated the circumstances surrounding his termination and that Global had the burden to prove the legality of the dismissal.

Global filed a petition for certiorari with the Court of Appeals (CA) under Rule 65, challenging the factual and evidentiary findings of the NLRC and the Labor Arbiter.
The CA reversed the NLRC’s and Labor Arbiter’s decisions by holding that the text messages and Reyes’ assertions did not meet the standard of "clear, positive and convincing evidence" to prove an illegal dismissal.
Petitioner's subsequent petition for review on certiorari before the Supreme Court under Rule 45 sought to reverse the CA’s decision.

Reyes contended that his filing of leave applications and subsequent text communications indicated his intention to continue employment, thereby negating the theory of abandonment.
Reyes maintained that the verbal instruction from Co Say, coupled with corroborative text messages, constituted a clear act of dismissal by an authorized superior.
Global argued that Reyes had violated company rules, thereby justifying his cessation of reporting, and that the evidence provided was inadequate to demonstrate that a dismissal had occurred.

The petitioner assigned multiple errors to the CA, including an erroneous interpretation of the evidence, a misapplication of the clear and convincing evidence standard, and the improper substitution of the CA’s own factual determinations over those of the Labor Arbiter and the NLRC.
The Court was asked to review whether procedural due process was afforded to Reyes and whether the verbal instruction from a high-ranking official sufficed as a valid act of dismissal.

Whether respondent Global Beer Below Zero, Inc. illegally dismissed petitioner Reyes by virtue of the verbal instruction from his immediate supervisor.
Whether the Court of Appeals erred in annulling and setting aside the decisions of the NLRC and the Labor Arbiter, which found in favor of Reyes.
Whether the CA improperly resolved questions that should have been confined to questions of law rather than factual determinations.
Whether the CA committed grave abuse of discretion by substituting its own findings for those of the administrative agencies.
Whether the text messages (including the use of the term “turnover”) should be construed as clear evidence of dismissal and severance of employment.
Whether Reyes’ act of filing for dismissal and sending subsequent text messages is more consistent with termination rather than abandonment of employment.
Whether the circumstances of the case warrant a relaxation of the strict evidentiary rules normally applied, particularly in labor cases.