Case Summary (G.R. No. 202542)
Background of the Case
Antonina Q. Agabin was employed by Angono Medics Hospital, Inc. as a staff midwife on September 1, 2002, with a monthly salary of P3,500. She sought a leave of absence from June 29, 2007, to September 15, 2007, to fulfill educational requirements, which was approved by her superior. Upon returning on September 15, 2007, she was scheduled to work but faced a confrontation with the hospital's president, Andres Villamayor, who dismissed her without due process. Agabin subsequently filed a complaint for illegal dismissal and sought separation pay and backwages.
Ruling of the Executive Labor Arbiter
In the December 19, 2008 decision, the Arbiter ruled Agabin was illegally dismissed, confirming her leave was properly sanctioned and her continued employment was intended. The Arbiter ordered AMHI and Villamayor to pay Agabin full backwages, separation pay, and other benefits, recognizing Villamayor's bad faith.
National Labor Relations Commission (NLRC) Ruling
The NLRC upheld the Arbiter’s ruling on December 16, 2009, confirming Agabin's illegal dismissal but limited her separation pay and backwages based on her refusal to accept an offer of reinstatement made during a January 2008 hearing. Both parties' motions for reconsideration were denied on February 26, 2010.
Court of Appeals Ruling
The Court of Appeals dismissed AMHI's appeal while reinstating the Arbiter's decision on April 27, 2012, asserting that AMHI’s offer of reinstatement lacked sufficient evidence for considering a limit on Agabin's compensation. The CA reversed NLRC's modifications about the computation of Agabin's monetary awards, stating that her separation pay was to be computed until the finality of her decision.
Res Judicata Argument
AMHI contended that the prior ruling in SP No. 113939 functioned as res judicata against the subsequent case, asserting both shared identical parties, subjects, and causes. Agabin countered that the legal issues were distinct and the focus of SP No. 114001 was solely on the computation of monetary awards, making the cases not conclusively adjudicated together.
Supreme Court Decision
The Supreme Court found AMHI's petition unmeritorious, upholding that the decisions concerning Agabin’s illegal dismissal were final and executory. It clarified that the computation of her awards remained open for determination despite AMHI's claims of res judicata; that only the finding of illegal dismissal was settled. The Court reiterated the principles surrounding full backwages and separation pay — that backwages should be calculated from the mome
...continue readingCase Syllabus (G.R. No. 202542)
Case Overview
- The case involves a Petition for Review on Certiorari filed by Angono Medics Hospital, Inc. (AMHI) against Antonina Q. Agabin regarding the Court of Appeals’ decisions that reversed earlier rulings related to Agabin's illegal dismissal.
- The issues stem from the computation of Agabin's separation pay and backwages after her employment ended on September 19, 2007.
Antecedents
- Antonina Q. Agabin was hired by AMHI as a staff midwife on September 1, 2002, with a monthly salary of P3,500.00.
- Agabin was permitted by her supervisors to pursue nursing studies while employed.
- She requested leave without pay from June 29, 2007, to September 15, 2007, for her studies, which was approved.
- Upon returning, she was included in the schedule but faced hostility from Villamayor, the hospital president, leading to her being told not to report for work.
- AMHI contended that Agabin abandoned her job, while Agabin argued she was illegally dismissed.
Ruling of the Executive Labor Arbiter
- The Arbiter ruled on December 19, 2008, that Agabin was illegally dismissed.
- The Arbiter found that AMHI failed to provide due process and that Agabin’s leave was duly approved.
- Agabin was awarded full backwages, separation pay, service incentive leave pay, 13th month pay, and attorney's fees.
- Villamayor was held jointly liable with AMHI due to bad f