Case Summary (G.R. No. 196249)
Factual Antecedents
The respondents filed complaints alleging illegal dismissal along with multiple claims for unpaid wages and benefits. They accused the petitioners of paying salaries below the minimum wage, failing to enroll them in the Social Security System, terminating their employment without just cause, and enforcing unreasonable working hours, among other grievances. The Labor Arbiter ruled in favor of the respondents, citing unlawful termination and awarded back wages and other monetary claims to various employees. The petitioners contested the ruling, claiming a lack of due process as their previous counsel failed to present a defense.
Ruling of the National Labor Relations Commission (NLRC)
The NLRC upheld the Labor Arbiter's decision, stating that the petitioners could not substantiate their claims against the respondents. It highlighted that the petitioners failed to provide evidence of salary payment and did not show compliance with the legal requirements for deducting facility values from wages. The NLRC confirmed the determination that the respondents were terminated without just cause and deserved back wages and separation pay.
Ruling of the Court of Appeals
Upon appeal by the respondents, the Court of Appeals affirmed the NLRC's ruling with modifications. It vacated the decisions regarding Ma. Gina Benitez and Demetrio Berdin, Jr., determining that they voluntarily abandoned their employment. The Court found that the petitioners did not provide sufficient evidence to counter the claims regarding the remaining respondents and upheld the award of money claims.
Issues Raised by Petitioners
The petitioners sought a reversal of the Court of Appeals' decision on the grounds that it erroneously concluded that Joel Ducusin was illegally terminated and failed to demonstrate that the claims for unpaid wages had been settled. They asserted that Ducusin abandoned his employment and that their documentary evidence should have been sufficient to show payment.
Petitioners' Arguments
In their appeal, the petitioners contended that Ducusin's non-attendance constituted abandonment of employment. They also claimed that they had compensatory documentation—such as payroll records and receipts—that proved the respondents were paid their due wages. They argued that the lower courts failed to appreciate the evidence that was available to them.
Respondents' Arguments
The respondents maintained that the petitioners did not adequately refute arguments regarding Ducusin’s illegal termination, and they insisted that the petitioners failed to meet their burden of proof concerning the monetary claims. They emphasized that the petition to the Supreme Court merely sought a re-evaluation of facts, which is beyond the scope of the Court’s review.
The Court's Ruling
The Supreme Court affirmed the decisi
...continue readingCase Syllabus (G.R. No. 196249)
Background of the Case
- This case is a Petition for Review on Certiorari filed by petitioners Rose Hana Angeles and Zenaida Angeles against multiple respondents, including Ferdinand M. Bucad and other employees.
- The petition challenges the November 30, 2010 Decision and March 22, 2011 Resolution of the Court of Appeals (CA) which affirmed the previous rulings of the National Labor Relations Commission (NLRC) regarding illegal dismissal and money claims.
Factual Antecedents
- The case arises from consolidated complaints for illegal dismissal and money claims filed by the respondents against the petitioners' establishments: Las Marias Grill and Restaurant and CafA Teria Bar and Restaurant.
- Respondents alleged underpayment of wages, non-coverage under the Social Security System (SSS), illegal termination without benefits, and various unpaid allowances and claims.
- Specific claims included long working hours, verbal abuse, and maltreatment by the petitioners.
- Notably, Joel Ducusin, Ma. Gina Benitez, and Demetrio L. Berdin Jr. filed for illegal dismissal, while others raised various accusations of labor law violations.
Labor Arbiter's Decision
- The Labor Arbiter's decision on June 30, 2000, found Zenaida Angeles guilty of illegal dismissal concerning Ducusin, Benitez, and Berdin Jr., awarding them back wages and various unpaid claims totaling P1,287,120.71.
- Other claims from respondents were denied for lack of merit. The petitioners did not submit a Position Paper to contes