Case Summary (G.R. No. 210308)
Factual Antecedents
Cavite Apparel, a domestic corporation engaged in the garment manufacturing sector, hired Michelle Marquez on August 22, 1994, as a regular employee. Over the years, she enjoyed benefits, including vacation and sick leave. Prior to her dismissal on June 8, 2000, she accumulated several infractions for Absence Without Leave (AWOL), receiving various penalties, including written warnings and suspensions. Following a period of illness, during which she submitted medical certificates, Cavite Apparel nonetheless terminated her employment, citing habitual absenteeism as the reason.
The LA Ruling
In a ruling dated April 28, 2001, Labor Arbiter Cresencio G. Ramos dismissed Michelle's complaint for illegal dismissal. The LA found her attendance record unacceptable, characterizing her absences as constituting gross neglect of duty, thus justifying her termination. The LA determined that due process had been followed, as Michelle had been given opportunities to explain her absences beforehand.
The NLRC Decision
Michelle appealed the LA's decision to the National Labor Relations Commission (NLRC), which reviewed the case, leading to a reversal on May 7, 2003. The NLRC disagreed with the LA's findings, asserting that Cavite Apparel had already penalized Michelle for her earlier infractions, and concluded that her dismissal was illegal given the disproportionate penalty associated with her conduct over six years of service.
The CA Ruling
Cavite Apparel petitioned the Court of Appeals (CA) for certiorari, contesting the NLRC's findings. The CA dismissed this petition on January 23, 2006, finding no grave abuse of discretion by the NLRC. It acknowledged that while habitual absenteeism could warrant dismissal, Michelle’s circumstances—including her submission of medical documentation—did not meet the threshold for such a penalty, especially in light of her years of dedicated service.
The Petition
Cavite Apparel raised several points of contention related to the CA's dismissal of their petition, arguing that the NLRC had erred in its judgment and that Michelle's AWOLs should be viewed as habitual. They contended that their management prerogative allowed for her dismissal based on perceived misconduct.
The Case for the Respondent
Michelle, countering Cavite Apparel's claims, argued that her dismissal was unwarranted given her long tenure and minimal record of absenteeism. She asserted that her absences were due to medical reasons and emphasized that the penalties applied to her previous infractions should not lead to her termination.
The Court's Ruling
The Court affirmed the CA's ruling, insisting that it does not review factual matters but rather legal ones, confirming that the NLRC had not acted with grave abuse of discretion. The CA and NLRC concluded that Michelle's absence pattern did not reflect gross and habitual neglect of duty, especially as her infractions were infrequent in the context of her six years of employment.
Proportionality o
...continue readingCase Syllabus (G.R. No. 210308)
Case Background
- This case involves a petition for review on certiorari by Cavite Apparel, Incorporated and Adriano Timoteo against Michelle Marquez, concerning her alleged illegal dismissal from employment.
- The petitioners sought to nullify the decisions made by the Court of Appeals that affirmed the ruling of the National Labor Relations Commission (NLRC).
- The NLRC reversed the Labor Arbiter's decision which had dismissed Michelle's complaint for illegal dismissal.
Factual Antecedents
- Cavite Apparel is a domestic corporation that manufactures garments for export.
- Michelle Marquez was employed as a regular employee in the Finishing Department since August 22, 1994, and was entitled to vacation and sick leaves.
- Prior to her dismissal on June 8, 2000, Michelle committed multiple absences without leave (AWOL):
- First Offense: December 6, 1999 - received a written warning.
- Second Offense: January 12, 2000 - received a stern warning and a three-day suspension.
- Third Offense: April 27, 2000 - received a six-day suspension.
- Following a medical absence from May 8, 2000, and subsequent absences from May 15-27, 2000, Cavite Apparel terminated Michelle's employment on the basis of habitual absenteeism.
Labor Arbiter's Ruling
- Labor Arbiter Cresencio G. Ramos ruled in favor of Cavite Apparel, asserting that Michelle's absences constituted habitual neglect of duty.
- The Arbiter stated that due process was observed during Michelle's dismissal and deemed it valid due to her repeated infractions.