Case Digest (G.R. No. 116025)
Facts:
Sunshine Transportation, Incorporated v. National Labor Relations Commission and Realucio R. Santos, G.R. No. 116025, February 22, 1996, Supreme Court Third Division, Davide Jr., J., writing for the Court.Petitioner Sunshine Transportation, Inc. employed respondent Realucio R. Santos as a probationary bus driver on August 24, 1989 and regularized him as Bus Driver Class C on March 16, 1990. On January 4, 1992 the company sent Santos a memorandum directing him to submit a written explanation within 48 hours for his alleged failure to report for a trip on December 28, 1991. Santos maintained that he had applied for leave on January 2, 1992 to Operations Manager Danilo Alvarado, who allegedly tore the leave form, verbally terminated him, and forced him off the premises; Santos then mailed a leave application the same day.
Santos received a termination letter dated January 22, 1992, citing insubordination for failure to submit the written explanation and treating such failure as an admission of guilt, but he continued to report for work and was thereafter refused entry, leading him to believe he was suspended or dismissed. On December 21, 1992 Santos filed a complaint with the Labor Arbiter alleging illegal suspension and dismissal, illegal deductions, unpaid salaries and allowances, overtime, premiums, separation pay, and sought reinstatement with back wages and moral damages.
Labor Arbiter Eduardo J. Carpio, in a decision dated June 30, 1993, dismissed Santos’s complaint, finding dismissal for cause with due process and denying his money claims. Santos appealed to the NLRC, which, in a decision dated April 21, 1994 (NLRC Case No. 00528 1-93), upheld the Labor Arbiter's finding of dismissal for cause but nevertheless awarded Santos money claims of P158,000.00 after concluding the petitioner failed to refute his underpayment claim.
Petitioner filed a special civil action for certiorari under Rule 65 of the Rules of Court in the Supreme Court, assailing the NLRC decision for (1) not dismissing Santos’s appeal as patently defective for failure to perfect appeal, (2) modifying the Labor Arbiter’s decision by granting money claims without basis, (3) holding some 1989 claims not prescribed, and (4) failing to consider a quitclaim Santos allegedly executed on October 20, 1992...(Pro-only)
Issues:
- Was the Rule 65 petition properly filed in the Supreme Court, i.e., did the petitioner show that there was no plain, speedy, and adequate remedy in the ordinary course of law so as to justify bypassing available administrative remedies?
- Did the NLRC commit grave abuse of discretion in (a) modifying the Labor Arbiter’s decision to grant Santos P158,000.00 without factual or legal basis, (b) ruling that certain 1989 claims had not prescribed, and (c) failing to c...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)