Case Summary (G.R. No. 178409)
Factual Background
On May 7, 1991, the drivers were required to sign individual contracts of lease to formalize their employment relationship, which they perceived as a prerequisite to continuing their current roles. Following their refusal to sign, the drivers stopped working and subsequently filed a complaint for illegal dismissal with the Labor Arbiter on May 14, 1991, although they initially sought separation pay rather than reinstatement. Fourteen of the drivers later returned to work, leaving eight to pursue the complaint.
Labor Arbiter's Decision
The Labor Arbiter ruled against the petitioners, concluding there had been no dismissal, but rather an abandonment of work due to misunderstanding. It found that the petitioners’ assertions about a voluntary job abandonment were not well founded, as it is unlikely that they would dismiss multiple employees simultaneously due to its impact on operations. The Arbiter directed the petitioners to reinstate the drivers, affirming their entitlement to return to their previous positions without loss of seniority or benefits, though without back wages.
Appeal to the National Labor Relations Commission (NLRC)
The private respondents appealed to the NLRC, reiterating their demand for separation pay and back wages. The NLRC upheld the Labor Arbiter's finding of misunderstanding but modified the relief granted. It ruled that due to the strained relationship, which arose from the misunderstanding, it would be prudent for the petitioners to provide the drivers with half a month's salary for each year of service as separation pay.
Petitioner's Argument Against NLRC Decision
The petitioners contended that the award of separation pay was unwarranted as the Labor Arbiter had already determined there was no illegal dismissal, but rather an abandonment of work. They argued that awards of separation pay are typically reserved for cases of illegal dismissal and cited Article 279 of the Labor Code, which prescribes reinstatement for employees dismissed without cause.
Supreme Court Analysis
The Supreme Court agreed with the petitioners, stating that there was no ground for separation pay since there was no dismissal involved—only a misunderstanding that led to the drivers' cessation of work. The Court clarified that reinstatement should not be
...continue readingCase Syllabus (G.R. No. 178409)
Case Citation
- G.R. No. 117378
- Date of Decision: March 26, 1997
- Jurisdiction: Supreme Court of the Philippines
Parties Involved
- Petitioners: Gil Capili and Ricardo Capili
- Respondents: National Labor Relations Commission, Benigno Santos, Delfin Yuson, Luisito Santos, Ursino Basister, Ricardo Reyes, Joselito Santos, Jorge Binuya, Nicolas Mulingbayan
Background of the Case
- Respondents are licensed drivers of public utility jeepneys operating the Libertad-Sta. Cruz route in Manila, previously owned by petitioner Gil Capili.
- Drivers paid a daily boundary of P280.00 to operate the jeepneys, yielding a net profit of P200.00 per day.
- On May 7, 1991, when petitioners required drivers to sign lease contracts to formalize the lessee relationship, the drivers stopped working, believing signing was mandatory.
- On May 14, 1991, twenty-two drivers filed a complaint for illegal dismissal, seeking separation pay rather than reinstatement.
- Fourteen drivers resumed work, leaving eight complainants with varying employment tenures.
Labor Arbiter's Decision
- The Labor Arbiter identified the situation as one of misunderstanding rather than dismissal or abandonment.
- Found that the drivers boycotted work due to the misunderstanding regarding the necessity of signing the lease contracts.
- Concluded that both parties misapprehended the situation and ordered reinstatement without loss of seniority rights, but without back