G.R. No. 167727 - Crayons Processing, Inc. vs. Pula

Case Summary (G.R. No. 167727)

Factual Background

Pula was employed as a Preparation Machine Operator until he suffered a heart attack on November 27, 1999. Following the heart attack, he was hospitalized for one week, and upon his release, he was advised by his physician to take a three-month leave. After undergoing an angiogram in February 2000 and receiving further medical advice, Pula reported back to work on April 11, 2000, but claimed he wasn’t given any work assignments. Instead, on June 20, 2000, he was allegedly asked to resign with an offer of P12,000 in financial assistance, which he refused.

Initial Labor Arbiter Decision

Pula subsequently filed a complaint for illegal dismissal against Crayons and several individuals associated with the company. The Labor Arbiter, Marita V. Padolina, found Pula's dismissal to be illegal, ordering his reinstatement with back wages and other monetary claims. The Labor Arbiter emphasized that the company’s arguments were lacking in substantive evidence, deeming their position to be a last-ditch effort to undermine Pula's claims and unlawfully deny him employment.

National Labor Relations Commission Appeal

On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, concluding there was valid cause for Pula's termination based on his prolonged illness, which had kept him away from his job for over six months. The NLRC contended that no official medical certification was necessary since the duration of Pula's absence sufficed for dismissal. Pula contested this conclusion by filing a special civil action for certiorari with the Court of Appeals.

Court of Appeals Ruling

The Court of Appeals reinstated the Labor Arbiter’s decision, rejecting the NLRC's findings. The appellate court noted that Crayons failed to clearly deny Pula's allegations regarding his lack of work assignments post his return, and thus those allegations were deemed admitted. Furthermore, the Court of Appeals dismissed Crayons' attached report, prepared by its HR manager, as hearsay since it was not presented or endorsed in the lower proceedings and lacked probative value.

Supreme Court Review

Upon appeal to the Supreme Court, Crayons asserted that the Court of Appeals erred in dismissing the HR report, claiming it had significant implications. However, the Supreme Court upheld the Court of Appeals’ refusal to admit the report, emphasizing that the report's late introduction and its unverified nature diminished its reliability. It reaffirmed the principle that clients are responsible for their counsel’s actions, except in cases of gross negligence, which was not demonstrated in this instance.

Legal Standards for Termination Due to Illness

The Court elaborated on the requirements outlined in Article 284 of the Labor Code concerning termination due to disease. For a dismissal to be valid, the