Case Summary (G.R. No. 171916)
Background of the Case
The petitioner is a corporation engaged in the printing business located in Makati. Due to the expiration of its lease agreement and local government issues regarding the safety of its plant, the petitioner decided to relocate its operations to Sto. Tomas, Batangas. The transfer prompted the petitioner to inform employees about their choice to either move with the company or face potential replacement. Subsequent communications revealed that the employees were largely unwilling to make the move, leading to a situation where some opted for financial assistance while others filed a complaint against the petitioner for various labor grievances including unfair labor practice and illegal dismissal.
Labor Arbiter Decision
The labor arbiter ruled on October 27, 1994, that the transfer of the business was valid and that no unfair labor practice or illegal dismissal occurred. However, the arbiter ordered the petitioner to pay separation pay and other claims, including 13th month pay and legal holiday pay. The arbiter recognized the business's transfer as a cessation of operations in Makati, entitling the employees to benefits under the Labor Code.
NLRC Ruling
Upon appeal, the NLRC affirmed the labor arbiter's decision but modified it by removing the award of attorney's fees, citing a lack of legal and factual basis. The public respondent concluded that the labor arbiter's decision had sufficient justification regarding separation pay but lacked clarity on the justification for attorney’s fees.
Arguments Presented by the Petitioner
The petitioner contended that its business relocation did not constitute a closure or retrenchment, thus no separation pay was warranted. It argued that the employees voluntarily resigned due to the distance of the new location. These contentions were met with skepticism, as the court maintained that the relocation effectively ceased operations in Makati, thus legitimizing the separation pay claim.
Legal Basis for the Decision
Under Article 283 of the Labor Code, closures or cessation of business operations entitle employees to separation pay unless such closures are due to serious business losses. The court confirmed that as the business was relocated for reasons beyond the employer's control, employees are entitled to compensation.
Clarification on Resignation and Claims
The court noted that claims of resignation from the employees did not align with their subsequent filing of a complaint for illegal dismissal. Resignation imp
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Case Overview
- This case involves a special civil action for certiorari filed by Cheniver Deco Print Technics Corporation (petitioner) against the National Labor Relations Commission (NLRC) and CFW-Magkakaisang Lakas ng mga Manggagawa sa Cheniver Deco Print Technics Corporation, along with individual respondents, including Edgardo Viguesilla.
- The petition seeks to annul the NLRC's resolutions dated May 31, 1995, and August 14, 1995, which affirmed the labor arbiter’s decision regarding the separation pay and other claims of the private respondents.
Background Information
- Cheniver Deco Print Technics Corporation is a duly organized corporation operating in Makati, engaged in the printing business.
- The private respondent labor union is affiliated with the Confederation of Free Workers (CFW), representing former employees of the petitioner.
- On June 5, 1992, the petitioner announced the relocation of its business from Makati to Sto. Tomas, Batangas, due to the expiration of its lease and local governmental actions regarding the plant's hazards.
- Employees were given until the end of June 1992 to express their willingness to relocate; otherwise, they would be replaced.
Employee Response to Relocation
- The last day of operation in Makati was set for June 29, 1992, followed by a temporary shutdown for the move.
- A letter dated August 4, 1992, was sent to employees, urging them to report to the new location within seven days, failing which they would be considered to have lost interest in their jobs.
- Despite the union's communication indicati