Facts:

The case involves Allan Villar, Danilo Indita, Arturo Manimtim, Gerson Datalio, Gerry Villaralbo, Alfonso Pipino, Noel Angay, and Exequiel Manimtim (collectively referred to as "petitioners") against the National Labor Relations Commission (NLRC) and Hi-Tech Manufacturing Corporation (Hi-Tech) as respondents. The events leading to this case began in March 1994 when the petitioners, who were employees of Hi-Tech engaged in manufacturing cartons, filed a petition for a certification election to form a labor union. The election took place on July 31, 1994, but the petitioners lost as the majority of employees voted for "No Union." Following this defeat, the petitioners did not report for work starting August 1, 1994, claiming they were barred from entering the premises. They subsequently filed separate complaints for illegal dismissal and labor standards violations against Hi-Tech, its owner Herman T. Go, and general manager Carmen Belano. The petitioners all...

Facts:

Employment and Union Activity:

• HI-TECH Manufacturing Corporation (HI-TECH) is a company engaged in manufacturing cartons for commercial purposes.
• Petitioners (Allan Villar, Danilo Indita, Arturo Manimtim, Gerson Datalio, Gerry Villaralbo, Alfonso Pipino, Noel Angay, and Exequiel Manimtim) were hired by HI-TECH for various positions such as slitter machine operator, inkman, silk screen printer, truck helper, rubber dye setter, forklift operator, and stitching machine operator.
• In March 1994, petitioners, who were members of the Federation of Free Workers Union, filed a petition for a certification election among HI-TECH's rank-and-file employees. The election was held on 31 July 1994, but the employees voted for "No Union," resulting in the petitioners' loss.

Alleged Dismissal and Claims:

• On 1 August 1994 and the following days, petitioners failed to report for work, claiming they were barred from entering HI-TECH's premises.
• They filed complaints for illegal dismissal and labor standards violations, alleging they were dismissed in retaliation for organizing a union and filing the certification election petition.
• Petitioners also claimed they were underpaid, worked overtime without compensation, and were denied service incentive leave pay and 13th month pay.

HI-TECH's Defense:

• HI-TECH denied dismissing the petitioners, arguing that they voluntarily stopped working after losing the certification election.
• The company presented affidavits from employees who initially joined the complaint but later desisted, stating they were not dismissed and had no claims against HI-TECH.
• HI-TECH also submitted handwritten notes from petitioners Arturo Manimtim and Exequiel Manimtim, wherein they apologized for their actions and sought financial assistance.

Labor Arbiter's Decision:

• On 15 August 1996, the Labor Arbiter ruled in favor of the petitioners, ordering their reinstatement with full back wages and payment of monetary benefits.

NLRC's Reversal:

• On appeal, the NLRC reversed the Labor Arbiter's decision, ruling that petitioners voluntarily resigned and were not illegally dismissed. The NLRC ordered petitioners to return to work or receive separation benefits.

Issue:

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Ruling:

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Ratio:

1. Abandonment of Work:

   • Abandonment requires clear proof of a deliberate and unjustified intent to sever the employer-employee relationship. Mere absence from work is insufficient.
   • The immediate filing of complaints for illegal dismissal negates the claim of abandonment. Petitioners' actions showed they did not intend to abandon their jobs.

2. Burden of Proof in Termination Cases:

   • The burden of proving that an employee voluntarily resigned or abandoned their job rests on the employer.
   • HI-TECH failed to provide substantial evidence to prove that petitioners abandoned their jobs.

3. Monetary Claims:

   • The burden of proving payment of wages and benefits rests on the employer. HI-TECH failed to provide evidence that it paid petitioners their rightful wages and benefits.
   • Petitioners' claims for underpayment, 13th month pay, and service incentive leave pay were valid and supported by their joint affidavit.

4. Quitclaims:

   • Quitclaims or deeds of release do not bar employees from claiming benefits they are legally entitled to. However, any amounts received as consideration for the quitclaims should be deducted from the monetary awards.

Conclusion:

The Supreme Court granted the petition, set aside the NLRC's decision, and reinstated the Labor Arbiter's ruling. HI-TECH was ordered to reinstate petitioners with full back wages and pay their monetary benefits, with deductions for amounts received under quitclaims by Arturo Manimtim and Exequiel Manimtim.