G.R. No. 140853 - Tres Reyes vs. Maxim's Tea House

Ariel A. Tres Reyes was employed by Maximas Tea House as a driver since October 1995.
He was assigned to the Ermita, Manila branch on M.H. del Pilar Street with his working hours set from 5:00 P.M. to 3:00 A.M.
His duties included transporting employees home after the restaurant closed.

On September 27, 1997, while driving a Mitsubishi L300 van to fetch employees of Savannah Moon in Libis, Quezon City, Tres Reyes encountered a hazardous situation.
Traveling at 50–60 km/h along Julia Vargas Street in Pasig City toward Meralco Avenue, he observed a ten-wheeler truck speeding head-on despite approaching a red signal light.
In an effort to avoid a collision, Tres Reyes maneuvered his vehicle; however, the van still struck the truck causing injuries to the petitioner and seven passengers, as well as damage to both vehicles.

On October 15, 1997, Maximas Tea House requested that Tres Reyes submit a written explanation within 48 hours regarding the incident.
Although he complied, the employer deemed his explanation unsatisfactory.
Consequently, Tres Reyes was placed under a preventive suspension for 30 days effective October 20, 1997, and was subsequently terminated on November 19, 1997 for cause.

Tres Reyes filed a complaint for illegal dismissal (NLRC NCR Case No. 00-12-08773-97), asserting that the vehicular accident did not justify his termination.
On July 20, 1998, the Labor Arbiter ruled in favor of the respondent (Maximas Tea House) by sustaining the dismissal on the ground that Tres Reyes was grossly negligent in failing to avoid the collision.
The award granted by the Labor Arbiter included the payment of financial assistance, 13th month pay, and service incentive leave pay amounting to a total of ₱11,788.00.

Instead of a formal appeal, Tres Reyes filed a Motion for Partial Reconsideration on October 8, 1998.
The NLRC treated this motion as an appeal (NLRC CA No. 017339-98) and, on March 11, 1999, reversed the Labor Arbiter’s decision.
The NLRC ordered the reinstatement of Tres Reyes with full backwages or, alternatively, the payment of separation pay calculated by the duration of his service along with backwages.
Respondents filed a motion for reconsideration which was later denied on May 12, 1999.

The respondents then elevated the case by filing a special civil action for certiorari with the Court of Appeals (CA-G.R. SP No. 54110).
The respondents alleged that the NLRC had committed grave abuse of discretion:

By treating Tres Reyes' motion for partial reconsideration as an appeal despite procedural prohibitions.
By substituting its own findings for those of the Labor Arbiter.

On November 22, 1999, the Court of Appeals set aside the NLRC decision, ruling in favor of the respondents and dismissing Tres Reyes’ complaint for lack of merit.

Concluding that the NLRC committed grave abuse of discretion in treating his Motion for Partial Reconsideration as an appeal.
Upholding the finding of gross negligence based on purported observations of demeanor during hearings which did not actually take place.

Tres Reyes emphasized that his motion complied with the NLRC procedural requirements by:

Being properly filed, verified, and submitted within the reglementary ten-day period from receipt of the decision.
Having paid the required appeal fee as evidenced by the cash payment and the corresponding official receipt.

He further argued that the factual evidence, particularly the police report, supported that the accident was primarily caused by the ten-wheeler truck running a red light and losing brake control, not by his own negligence.

Whether the Motion for Partial Reconsideration filed by Tres Reyes could be treated as a valid appeal under the NLRC Rules of Procedure.

The petitioner argued that his motion, though called a “motion for reconsideration,” was in substance an appeal meeting all technical requisites (timeliness, verification, payment of fees).
The respondents maintained that the formal rule explicitly prohibits such a motion as an appeal unless all procedural requirements are strictly complied with.

Whether the dismissal of Tres Reyes from employment was valid and legal based on the allegation of gross negligence.

Tres Reyes challenged the finding of gross negligence which led to his termination, asserting that the evidence, particularly the police report, exonerated him.
The Court of Appeals’ reliance on the notion that a trial-type hearing provided an opportunity to observe the demeanor of the litigants was also questioned given that no such trial was conducted at the Labor Arbiter’s level.