G.R. No. 181483 - Blazer Car Marketing, Inc. vs. Spouses Bulauan

Petitioners are Blazer Car Marketing, Inc. and its owner, Freddie Chua.
Respondents are spouses Tomas Bulauan and Analyn Briones, former employees of the petitioners.
Briones was employed as a secretary/warehouse clerk since April 29, 1998, while Bulauan worked as a driver from December 4, 1999, until May 4, 2002, and was rehired on March 24, 2003.
On November 18, 2003, Briones filed a complaint for illegal dismissal, non-payment of 13th month pay, and separation pay, followed by Bulauan filing a similar complaint on December 15, 2003.

Briones alleged that she was dismissed after confronting Chua about the remittance of SSS contributions and the issuance of her employee ID card.
Bulauan claimed he was dismissed after being confronted by Chua regarding his wife's actions.
Respondents argued that their dismissal was due to Chua's suspicion that they reported his illegal activities to the NBI.

Petitioners contended that Briones was caught making unauthorized company ID cards and that an investigation confirmed her actions.
Chua claimed that Briones was not dismissed and could return to work, but she chose not to.
Petitioners argued that Bulauan also failed to report for work after learning about the investigation into his wife.

The Labor Arbiter dismissed the complaints for illegal dismissal but ordered the payment of prorated 13th month pay to both respondents.
The decision was affirmed by the NLRC, which also denied the respondents' motion for reconsideration.

The CA reversed the NLRC's decision, declaring the respondents were illegally dismissed and entitled to backwages and separation pay.
The CA remanded the case to the NLRC for the determination of the amounts due to the respondents.

Petitioners maintained that the respondents were not dismissed but voluntarily left their jobs.
They argued that Briones' immediate filing of a complaint indicated she did not wish to continue her employment.

The Court upheld the CA's finding that the respondents were dismissed without just cause.
It emphasized that the filing of an illegal dismissal complaint contradicts claims of abandonment.
The Court found the petitioners' justification for dismissal to be contrived and lacking in credible evidence.

The Court noted that even if Briones made ID cards without authority, such conduct did not constitute serious misconduct warranting dismissal.
Misconduct must be serious, related to job performance, and demonstrate unfitness for continued employment.
The Court highlighted that Briones acted out of necessity to assist her co-employees, and no significant harm resulted from her actions.