Case Summary (G.R. No. 173256)
Background of Employment and Payment Structure
Dennis G. Lorenzo was employed by AFI as a processor starting April 12, 1991, while Cecilio S. Sorsan was hired on February 6, 1992, both receiving monthly wages initially. In March 1999, their mode of payment was shifted to a piece-rate system. Although AFI assured the respondents that this change would be temporary, they continued to receive payment on a piece-rate basis for several years.
Involvement of the Department of Labor and Employment
On January 14, 2002, the respondents approached the Department of Labor and Employment (DOLE) to inquire about the implications of this payment scheme on their employment status. Following this visit, when they reported to work on January 16, 2002, Raymundo informed them that they could no longer work and ordered them to leave the premises, effectively terminating their employment. When the respondents returned to the premises three days later, they were again barred from working and were told by Raymundo that they were already terminated.
Petitioners’ Claim of Just Cause for Dismissal
In defense, AFI contended that the respondents were dismissed for just cause due to gross and habitual neglect of duty, as they were allegedly absent from work without approved leave beginning January 16, 2002. The company argued that an explanation for these absences was requested on January 21, 2002, but respondents failed to respond, constituting neglect of duty.
Labor Arbiter's Decision
The Labor Arbiter ruled that there was illegal dismissal, indicating that for abandonment to justify dismissal, both intent to abandon and an overt act must be established. The Arbiter concluded that the dismissal was carried out without following the legal procedures necessary, thus categorizing it as illegal. The decision emphasized that there was no abandonment as the respondents had made efforts to return to work, and the subsequent notice from AFI appeared to be an afterthought.
NLRC Appeal and Ruling
Upon appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision. It contended that the Labor Arbiter had abused its discretion regarding the abandonment issue, stating that the five-day absence did not amount to gross neglect that could justify dismissal. The NLRC ruled that the respondents were voluntarily terminated and, as a result, were not entitled to backwages or separation pay.
Court of Appeals' Decision
The respondents subsequently filed a certiorari petition to the Court of Appeals. The Court set aside the NLRC's resolutions, stating that the dismissal lacked just cause and upholding the position that the absences did not justify termination. It awarded backwages and separation pay based on the absence of valid grounds for dismissal.
Arguments from Petitioners and Court's Analysis
In appealing to the Supreme Court, AFI asserted that the Court of Appeals committed reversible error by reversing the NLRC’s decision. They maintained that the respondents did not prove their claims of illegal dismissal. However, the Court reaffirmed the principle that the burden of proving valid cause for termination rests on the employer. The C
...continue readingCase Syllabus (G.R. No. 173256)
Background of the Case
- The case centers on illegal dismissal claims made by respondents Dennis G. Lorenzo and Cecilio S. Sorsan against petitioners AFI International Trading Corporation (AFI) and its general manager Celedonio Raymundo, Jr.
- Respondent Lorenzo was hired on April 12, 1991, and Sorsan on February 6, 1992, both as processors, initially paid monthly.
- In March 1999, AFI shifted to a piece-rate payment system, which was represented to be temporary but continued for several years.
Initiation of the Complaint
- Respondents sought clarification from the Department of Labor and Employment (DOLE) regarding the implications of the piece-rate payment on their employment status on January 14, 2002.
- Upon returning to work on January 16, 2002, they were informed by Raymundo that they could no longer work and were ordered to leave.
- Respondents attempted to return to work on January 19, 2002, but were again denied entry and informed of their termination.
Petitioners' Defense
- Petitioners claimed that termination was justified due to the respondents' unauthorized absences beginning January 16, 2002, and that they were required to explain these absences on January 21, 2002.
- They argued that the absences constituted gross and habitual neglect of duty, warranting dismissal.
Labor Arbiter's Decision
- The Labor Arbiter found that the dismissal w