Case Summary (G.R. No. 234725)
Facts of the Case
Roy R. Relucio, the respondent, filed a complaint with the Labor Arbiter against Bicol Isarog Transport System, Inc., along with its officers, alleging illegal dismissal, suspension, wage underpayment, and other labor-related claims. Relucio claimed he was unlawfully dismissed on March 30, 2013, after being suspended without due process. Conversely, Bicol Isarog contended that Relucio was a probationary employee initially and later became a regular employee and had violated company policies relating to the submission of reports and compliance with operational directives.
Legal Proceedings Overview
The Labor Arbiter dismissed Relucio's complaint, affirming that Bicol Isarog had sufficient grounds for dismissal, citing insubordination and procedural compliance in the termination process. The National Labor Relations Commission (NLRC) upheld the Arbiter's ruling. Unsatisfied with the NLRC's decision, Relucio appealed to the Court of Appeals, which later ruled in his favor on March 30, 2017, determining that his dismissal was illegal due to Bicol Isarog's failure to establish just cause and adhere to procedural due process.
Court of Appeals Decision
The Court of Appeals concluded that Bicol Isarog failed to meet its burden of proof regarding the just causes for termination and did not properly serve the requisite memoranda to Relucio. The CA emphasized that the notices regarding dismissal did not reach him, thus failing to provide him a chance to respond adequately. Consequently, the CA ordered Relucio's reinstatement and the payment of back wages and benefits.
Issues Presented
Bicol Isarog petitioned for review, arguing that it complied with procedural requirements for dismissal under the Labor Code and contending that Relucio's failure to report for duty constituted a substantial ground for dismissal. Relucio responded by asserting that he did not disregard any instructions, maintaining he was unavailable to meet the company representatives in Manila upon his return.
Substantive and Procedural Due Process
The Supreme Court emphasized the need to distinguish between substantive due process, which pertains to the existence of a valid cause for termination, and procedural due process, which concerns the manner in which the termination is executed. The employer bears the onus of proving compliance with both aspects. The dismissal for insubordination must be predicated on willful disobedience of lawful orders that are reasonable and relevant to the employee's duties.
Findings on Just Cause and Due Process Compliance
The Court found that the directives given to
...continue readingCase Syllabus (G.R. No. 234725)
Case Background
- The case involves a petition for review on certiorari by Bicol Isarog Transport System, Inc. (hereinafter referred to as "Bicol Isarog") against the decision and resolution of the Court of Appeals (CA) regarding the illegal dismissal of Roy R. Relucio (hereinafter referred to as "Relucio").
- The CA's decision, dated March 30, 2017, reversed the labor tribunals' findings, declaring that Relucio was illegally dismissed by Bicol Isarog.
- The issues at hand include claims of illegal dismissal, illegal suspension, underpayment of salaries/wages, non-payment of benefits, and damages.
Facts of the Case
- Relucio filed a complaint against Bicol Isarog and its officers, alleging illegal dismissal on March 30, 2013, after being suspended without due process.
- He asserted that he was not receiving required benefits such as ECOLA, PAG-IBIG, and Philhealth, and that his salary was underpaid.
- Bicol Isarog contended that Relucio was initially employed on a probationary basis and thereafter became a regular employee.
- The company claimed that Relucio repeatedly violated the company's Code of Discipline, specifically regarding the submission of the Trip Collection Report (TCR).
- Bicol Isarog issued memoranda requiring Relucio to explain his infractions and subsequently suspended him for 30 days for insubordination after he disobeyed an order not to proceed with a trip under certain conditions.
- Following further incidents of failure to report for work and lack of communication, Bicol Isarog issued termination notices to Relucio.
Labor Arbiter's Decision
- The Labor Arbiter dismissed Relucio’s complaint, ruling that there was just cause for his