Title
Antipolo Highway Lines, Inc. vs. Inciong
Case
G.R. No. L-38532
Decision Date
Jun 27, 1975
Crisostomo, dismissed for alleged fraud, filed for separation pay and reinstatement. NLRC ruled in his favor, ordering reinstatement with limited back wages, upheld by the Supreme Court.

Case Summary (G.R. No. 256288)

Factual Background

Crisanto Crisostomo, initially employed as an inspector and later as chief inspector at Antipolo Highway Lines, was dismissed on August 11, 1972, on allegations of involvement in a syndicate that defrauded the company of roughly P10,000. Following his dismissal, Crisostomo filed a claim for separation pay with the Department of Labor, which the company contested for lack of jurisdiction. Concurrently, Crisostomo initiated legal proceedings against De Jesus for estafa, and De Jesus countered with a claim against Crisostomo for estafa through falsification of documents.

Proceedings Before NLRC

Crisostomo formally complained before the NLRC on January 15, 1973, asserting that his dismissal was arbitrary and requesting separation pay and benefits. The case proceeded with conferences and hearings. The NLRC initially deferred the hearings because of the ongoing criminal cases. Once the criminal cases were dismissed, the NLRC held hearings, during which Crisostomo was present, but the company’s representation did not attend consistently.

NLRC Decision

On June 25, 1973, the NLRC arbitrator ruled that the dismissal of Crisostomo was without just cause and ordered reinstatement with full back wages amounting to P3,090, covering the ten-month period from dismissal to the decision's date. This decision was upheld through various administrative channels, including a resolution by the Secretary of Labor on March 19, 1974.

Petitioner's Contentions

Petitioners challenged the NLRC's order by filing a special civil action for certiorari, arguing they were denied due process since they were not provided a chance to fully present their evidence. They believed the NLRC acted with grave abuse of discretion and maintained that Crisostomo’s dismissal was justified due to entrenched misconduct.

Legal Analysis: Due Process and Jurisdiction

The Court examined whether the NLRC proceedings complied with due process requirements. It noted that while the NLRC procedural rules are more flexible than those in standard courts, the petitioners had multiple opportunities to present their case but opted not to pursue their claims actively. The absence of a comprehensive dispute over the jurisdiction of the NLRC was also acknowledged.

Conclusion on Findings

The Court found no merit in the petitioners' assertions of d

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