Case Summary (G.R. No. 121439)
Case Background
The petitioner, AKELCO, sought a writ of certiorari and prohibition, challenging the National Labor Relations Commission’s (NLRC) decision that reversed the Labor Arbiter's ruling which previously dismissed the complaints of private respondents for unpaid salaries, 13th month pay, and other fringe benefits. The NLRC ordered AKELCO to pay the private respondents a total of P 6,485,767.90 in back wages for the period from June 16, 1992, to March 18, 1993. The dispute arose following AKELCO's temporary transfer of its office from Lezo, Aklan, to Kalibo, Aklan, and the subsequent refusal of the complainants to comply with this directive.
Labor Arbiter's Findings
The Labor Arbiter asserted that the complainants voluntarily abandoned their positions by refusing to report to the new location despite lawful orders from management. The complainants had previously received payment for their salaries until May 1992, and were allowed to draw salaries again only from March 1993 forward. The Arbiter deemed that the "no work, no pay" principle applied, justifying the decision to dismiss the claims of the private respondents.
NLRC's Reversal
On appeal, the NLRC revived the claims of the private respondents, determining that they had indeed rendered services during the questioned period without receiving their due compensation. The NLRC based its conclusion on various documents and letters, including one from the Office Manager of AKELCO which acknowledged the request for salary payments. The NLRC found that the evidence did not support AKELCO's assertion that no services were rendered during the period in question.
Arguments from Petitioner
AKELCO contends that the NLRC committed grave abuse of discretion in reversing the Labor Arbiter's decision. The petitioner argued that the private respondents had openly defied management’s orders and subsequently cannot claim compensation under the "no work, no pay" principle. AKELCO also maintained that the evidence submitted by private respondents lacked substantiality and was self-serving.
Court's Analysis and Conclusion
The Supreme Court reiterated that it would not reassess the evidential basis of the NLRC's conclusion but would determine whether the NLRC acted with jurisdictional competence. The Court found that substantial evidence was indeed lacking in favor of the private respondents. The assertions th
...continue readingCase Syllabus (G.R. No. 121439)
Case Overview
- Court: Supreme Court of the Philippines
- Division: Third Division
- Case Number: G.R. No. 121439
- Date of Decision: January 25, 2000
- Petitioner: Aklan Electric Cooperative Incorporated (AKELCO)
- Respondents: National Labor Relations Commission (NLRC), Rodolfo M. Retiso and 165 Others
- Nature of the Case: Petition for certiorari and prohibition with prayer for writ of preliminary injunction and/or temporary restraining order.
Background of the Case
- The petitioner, AKELCO, challenges the NLRC’s decision dated April 20, 1995, which reversed the Labor Arbiter's ruling from February 25, 1994, that had dismissed the complaints of private respondents claiming unpaid wages.
- The NLRC ordered AKELCO to pay the private respondents a total of P6,485,767.90 for the period of June 16, 1992, to March 18, 1993.
- A temporary restraining order was issued by the Supreme Court on October 9, 1995, preventing the execution of the NLRC decision.
Facts of the Case
- Complaint Initiation: The complaints were filed by Rodolfo M. Retiso and 163 others against AKELCO and its officials for non-payment of salaries, 13th month pay, and other fringe benefits.
- Work Location Changes: Prior to the office transfer on January 22, 1992, complainants were working at Lezo, Aklan. Following the transfer to Kalibo, many employees continued to report at Lezo and received salaries until May 1992.
- Salary Non-Payment: From June 1992 to March 18, 1993, complainants did not receive salaries despite continuing duties at Lezo.
- Re