Case Summary (G.R. No. 81471)
Factual Background
Jose M. Chua began his employment with Chong Guan Trading in 1960 but was officially registered with the Social Security System only in 1972. In November 1983, Chua filed a complaint against Chong Guan Trading alleging illegal dismissal and non-payment of overtime and other benefits. The dismissal allegedly occurred after an incident on October 28, 1983, when a customer accidentally broke a showcase. Chua claimed he was dismissed by Mariano Lim, one of the owners, while the petitioner contended that Chua abandoned his post following the incident.
Procedural History
The Labor Arbiter initially ruled on April 18, 1984, finding no illegal dismissal but ordering Chua's reinstatement without backwages. Chua appealed this decision to the NLRC, which dismissed the appeal on June 30, 1987, for being filed out of time. However, the NLRC later reconsidered and ultimately ruled in favor of Chua on December 29, 1987, concluding that he had been illegally dismissed and ordering the petitioner to reinstate him with three years of backwages.
Jurisdictional Issues
The petitioner raised the jurisdiction of the NLRC to hear Chua's appeal, asserting that it had become final and executory after ten days per Article 223 of the Labor Code. The petitioner argued that Chua filed the appeal beyond the ten calendar days allowed. However, the Court allowed the NLRC to overlook this procedural lapse, noting that reliance on misleading language in the Labor Arbiter’s decision was a reasonable ground for excusing tardiness.
Main Issue: Illegal Dismissal
The fundamental issue addressed by the Court was whether the NLRC had acted with grave abuse of discretion in ordering backwages and separation pay for Chua's alleged illegal dismissal. The NLRC and Labor Arbiter concurred that the incident leading to Chua's alleged dismissal was minor, and the Court recognized that substantial evidence was lacking to prove a scheme by the petitioner to terminate him.
Evaluation of Evidence
The Court found that the NLRC's conclusion of a scheme to oust Chua was speculative and not supported by credible evidence. Notably, the petitioner had continued to provide Chua with cash advances prior to the incident, suggesting no intent to dismiss him.
Finding on Dismissal
Upon reviewing the events of October 28, the Court concluded that no formal dismissal occurred. Chua's failure to return to work was attributed to a misunderstanding rather than a clear intent from the petitioner to terminate his employment. Petiti
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Case Overview
- The case involves a petition filed by Chong Guan Trading against the National Labor Relations Commission (NLRC) and Jose M. Chua regarding the latter's alleged illegal dismissal.
- The NLRC previously ruled that Jose M. Chua was indeed illegally dismissed from his position as sales manager at Chong Guan Trading.
Background of the Case
- Jose M. Chua began his employment with Chong Guan Trading in 1960, although his name was officially registered with the Social Security System in 1972.
- In November 1983, Chua filed a complaint against Chong Guan Trading for illegal dismissal, non-payment of overtime, and other benefits.
- The incident leading to the complaint occurred on October 28, 1983, when a customer accidentally broke a showcase at the store.
Incident Details
- Following the incident, Chua admitted to Pepito Lim (one of the owners) that he broke the glass to cover for the customer.
- An altercation ensued, with Pepito Lim allegedly using abusive language towards Chua.
- Chua claimed that Mariano Lim ordered him to leave the premises, which he interpreted as dismissal, while the petitioner asserted that Chua voluntarily left and subsequently did not report for work.
Labor Arbiter's Decision
- The Labor Arbiter concluded that there was no illegal dismissal, determining that the incident was minor and did not warrant dismissal.
- The Arbiter ordered Chua's reinstatement without back wages, along with a proportionate 13th-month pay and service incentive leave pay, while dismiss