Case Summary (G.R. No. 242875)
Employment Background
In 2002, Augorio A. Dela Rosa was hired by ABS-CBN Corporation, a prominent entity in the Philippine broadcast industry, as a video editor. He was compensated at an hourly rate of PHP 230.00 and reportedly was rehired multiple times, engaged through fixed-term contracts. Notably, a serious incident occurred in 2013 when Dela Rosa reported to work intoxicated and harassed a female colleague, prompting disciplinary actions from the management.
Incident and Disciplinary Actions
After the incident involving inappropriate conduct on August 22, 2013, wherein Dela Rosa, while intoxicated, engaged in lewd behavior towards a co-worker, he received a show cause memorandum on August 23, 2013. He offered a defense on August 28, 2013, claiming the incident was accidental. Administrative hearings took place afterward, leading to a management decision on September 1, 2015, which indicated Dela Rosa's dismissal due to serious misconduct—even though it was stated that his contract expired before disciplinary action could be executed.
Labor Arbiter Ruling
In an October 28, 2016 decision by the Labor Arbiter (LA), it was determined that Dela Rosa was illegally dismissed. The LA ordered ABS-CBN to pay back wages, separation pay, and damages, asserting that Dela Rosa was a regular employee—thus entitled to security of tenure—and that his dismissal due to the "end of contract" was unlawful. The LA criticized the inconsistent rationale provided by the corporation about the dismissal.
NLRC Ruling
The National Labor Relations Commission (NLRC) affirmed the LA's ruling on April 27, 2017, but modified it by eliminating the award of moral and exemplary damages. The NLRC found that Dela Rosa was indeed a regular employee due to the continuity and nature of his engagement with ABS-CBN, and noted that his purported dismissal for serious misconduct could not stand since the basis for termination cited was the expiration of his fixed-term contract. A subsequent resolution on June 30, 2017, modified the computation of separation pay.
Court of Appeals Ruling
The Court of Appeals (CA) reversed the NLRC's findings in a decision dated June 19, 2018, ruling that Dela Rosa was validly dismissed for just cause due to serious misconduct. The CA found that the due process requirements of notice and hearing were satisfied, which included a show cause order and adequate representation during hearings. Dela Rosa's motion for reconsideration was denied in October 2018, prompting his petition to the Supreme Court.
Issue Presented to the Supreme Court
The principal issue considered was whether the CA erred in concluding that Dela Rosa was legally dismissed for just cause.
Supreme Court's Ruling
The Supreme Court found the petition partially meritorious. The Court emphasized the review framework in labor cases, noting that a grave abuse of discretion may arise when the NLRC's decisions are not supported by substantial evidence. The Court sided with the CA's position that serious misconduct justified Dela Rosa’s dismissal, based on the evidence of inappropriate behavior.
Definition and Context of Misconduct
The Court reaffirmed that misconduct entails improper conduct or transgressions of definite
...continue readingCase Syllabus (G.R. No. 242875)
Background of the Case
- The case involves a petition for review on certiorari filed by Augorio A. Dela Rosa (petitioner) against ABS-CBN Corporation (respondent).
- The petition assails the Decision dated June 19, 2018, and the Resolution dated October 22, 2018, of the Court of Appeals (CA) in CA-G.R. SP No. 152463, which upheld petitioner’s valid dismissal and denied his claims for backwages, separation pay, and attorney's fees.
Facts of the Case
- Petitioner was hired by ABS-CBN Corporation in 2002 as a video editor at an hourly rate of P230.00.
- He was rehired multiple times under fixed-term contracts for the same position.
- On August 22, 2013, petitioner reported to work while intoxicated and committed inappropriate acts towards a female co-worker, leading to a show cause memorandum issued on August 23, 2013.
- Petitioner claimed the incident was accidental, attributing it to losing his balance.
- Administrative hearings were conducted, and on September 1, 2015, management decided to impose the penalty of dismissal but claimed it could not be enforced due to the expiration of his employment contract.
Legal Claims by the Petitioner
- Petitioner filed a complaint for illegal dismissal, underpayment of holiday pay, non-payment of salary/wages, 13th month pay, separation pay, and damages against respondent.
- He contended that he was illegally dismissed and sought various monetary claims in his complaint.
Respondent's Position
- ABS-CBN Corporation argued that petitioner was engag