Case Summary (G.R. No. 138094)
Termination of Employment and Initial Proceedings
- Marilou Guanzon Apalisok, the petitioner, was employed as the Production Chief at Radio Philippines Network (RPN) Station DYKC.
- On May 15, 1995, she received a memorandum from her superior, George Suazo, requesting an explanation for her alleged hostile behavior.
- Following her response, she was informed on May 31, 1995, that her employment would be terminated effective June 15, 1995.
- Petitioner chose to waive her right to the grievance machinery outlined in the Collective Bargaining Agreement (CBA) and instead filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC).
Submission Agreement and Voluntary Arbitration
- The NLRC referred the case to the National Conciliation and Mediation Board, where both parties signed a Submission Agreement on June 20, 1995.
- This agreement stipulated that the dispute regarding the validity of the petitioner’s dismissal would be submitted to a voluntary arbitrator.
- In her position paper, the petitioner sought a declaration of invalid dismissal, separation pay, back wages, and damages.
Award by the Voluntary Arbitrator
- On October 18, 1995, the voluntary arbitrator ruled in favor of the petitioner, declaring her dismissal invalid.
- The arbitrator awarded her a total of P411,126.76, which included separation pay, back wages, moral and exemplary damages, service incentive leaves, and attorney's fees.
- Respondents filed a motion for reconsideration, which was denied, prompting them to seek certiorari from the Supreme Court.
Court of Appeals Decision
- The Supreme Court referred the case to the Court of Appeals, which subsequently nullified the voluntary arbitration award.
- The Court of Appeals reasoned that the petitioner’s choice to bypass the grievance machinery effectively relinquished her right to voluntary arbitration, thus lacking jurisdiction over the case.
Supreme Court Ruling on Jurisdiction
- The Supreme Court found that the voluntary arbitrator had jurisdiction over the dispute, as both parties had agreed to submit the issue to arbitration.
- Article 262 of the Labor Code was cited, affirming that voluntary arbitrators can hear and decide labor disputes upon mutual agreement.
- The Court concluded that the voluntary arbitration process was not imposed on t...continue reading
Case Syllabus (G.R. No. 138094)
Case Overview
- This case involves a petition for review on certiorari filed by Marilou Guanzon Apalisok (petitioner) against Radio Philippines Network (RPN) and Station Manager George Suazo (respondents).
- The petition seeks to challenge the Court of Appeals Decision dated October 30, 1998, and the subsequent Resolution dated February 26, 1999.
Background Facts
- On May 15, 1995, Marilou Guanzon Apalisok, who was the Production Chief at RPN Station DYKC, received a memorandum from Gilito Datoc, the Branches Operations Manager.
- The memorandum requested a written explanation regarding allegations of her hostile actions towards RPN and her disrespectful behavior towards her superior, George Suazo.
- Apalisok submitted her answer on May 16, 1995, addressing the allegations.
- On May 31, 1995, she received another memorandum from the Administrative Manager stating that her services would be terminated effective June 15, 1995.
Waiver of Grievance Machinery and Filing of Complaint
- On June 5, 1995, Apalisok waived her right to address the case through the grievance machinery stipulated in the Collective Bargaining Agreement (CBA) and opted to file her case before the proper government forum.
- She subsequently filed a complaint for illegal dismissal against RPN DYKC and Suazo with the National Labor Relations Commission (NLRC), which referred the case to the National Conciliation and Mediation Board.