Case Digest (G.R. No. 231859) Core Legal Reasoning Model
Facts:
Gerardo C. Roxas, the petitioner, was employed as a bus driver by Baliwag Transit, Inc. (BTI) since March 24, 1998, on a commission basis. In 2012, the bus assigned to him was phased out according to the Land Transportation Franchising and Regulatory Board (LTFRB) Resolution No. 2013-01, significantly reducing his work assignment from a regular three-week duty to only two weeks per month. On June 5, 2014, dissatisfied with this change, Roxas filed a complaint for constructive dismissal, among other claims, against BTI and its owner, Joselito S. Tengco, before the National Labor Relations Commission (NLRC) in the National Capital Region, under NLRC RAB NCR Case No. NCR-06-06790-14. During a scheduled hearing on July 2, 2014, Roxas was informed about a duty assignment but failed to comply due to his obligation to attend the hearing, leading to a notice of abandonment from BTI. His first complaint was dismissed on October 15, 2014, for improper venue. Subsequently, Roxas filed a s
Case Digest (G.R. No. 231859) Expanded Legal Reasoning Model
Facts:
Roxas, employed by Baliwag Transit, Inc. (BTI) since March 24, 1998 as a bus driver paid on a commission basis, was assigned to work on buses that were ultimately phased out due to a government directive (LTFRB Resolution No. 2013-01). With the phase-out, his work schedule was reduced from a regular three‑week duty to only two weeks per month—a scheme that affected all drivers and conductors. Feeling aggrieved by the reduction which resulted in diminished pay and benefits, Roxas initially filed a complaint for constructive dismissal, non-payment of various benefits, illegal suspension, and other money claims before the NLRC-NCR. At the scheduled hearing, Roxas notified BTI of his inability to render service on the designated day, only to be warned against abandonment. After a notice to explain his absence resulted in Roxas clarifying his position, his first complaint was dismissed for improper venue. Subsequently, Roxas re‑filed (as his second complaint) before the Regional Arbitration Board (RAB) III, alleging constructive dismissal effective June 4, 2014, and further claims arose concerning non‑payment of benefits and allegations of oppressive treatment. In response, BTI argued that Roxas was a disgruntled employee whose actions—refusing to provide additional explanations, labeling the investigating officer a liar, and not reporting for work—amounted to insubordination, serious misconduct, and abandonment. Notably, on July 21, 2015, Roxas was issued a notice of termination based on these alleged grounds.Issues:
- Whether the reduction of Roxas’s work assignment under a government-induced scheme constituted constructive dismissal or a mere exercise of BTI’s management prerogative.
- Whether the eventual termination of Roxas—grounded on allegations of gross misconduct, insubordination, and abandonment—was justified and supported by substantial evidence.
- Whether, considering the circumstances, Roxas is entitled to reinstatement (with full backwages and benefits) or separation pay, and the validity of his other money claims (including for 13th month pay, illegal deductions, and moral and exemplary damages).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)