Case Summary (G.R. No. 222992)
Facts of the Case
Jose R. Dela Torre was hired as a security guard by Twinstar Professional Protective Services, Inc., and was assigned at Las Haciendas in Tarlac City, earning a daily wage of P240.00. In January 2011, he sought help from a media personality for alleged underpayment of wages. He was later placed on floating status and subsequently did not report for duty, which led to him filing a complaint for illegal dismissal and non-payment of salaries on August 23, 2011. After an initial decision favoring him by the Labor Arbiter, Twinstar's appeal to the National Labor Relations Commission (NLRC) dismissed the claim, asserting that he did not incur constructive dismissal.
Ruling of the Labor Arbiter
On March 19, 2012, the Labor Arbiter ruled that Dela Torre had been constructively dismissed. The decision ordered Twinstar to pay backwages amounting to Php118,664.83 and separation pay of Php157,560.00. Twinstar appealed this decision to the NLRC.
Defense and Ruling of the NLRC
Twinstar argued that Dela Torre had been absent without leave (AWOL) since January 21, 2011, and provided evidence of attempts to make him return, including notices to report for duty. The NLRC, in a decision dated August 16, 2012, reversed the Labor Arbiter’s ruling, deeming there was no constructive dismissal but acknowledged procedural due process was not followed in the termination. The NLRC emphasized the existence of a valid Quitclaim signed by Dela Torre, dismissing the complaint for lack of merit.
Ruling of the Court of Appeals
The Court of Appeals, in its decision on September 3, 2015, upheld the NLRC’s ruling, stating that the admission of Twinstar's evidence during the appeal was not an abuse of discretion. It further validated the Quitclaim and denied Dela Torre's appeal for nominal damages, citing procedural infirmities in the termination process were alleviated by the Quitclaim.
Issues Presented
- Whether the CA erred in admitting Twinstar's new evidence submitted during the appeal.
- Whether the CA erred in determining that Dela Torre was not illegally dismissed.
- Whether the CA erred in denying the award of nominal damages due to the Quitclaim.
Supreme Court's Ruling
The Supreme Court denied the petition but recognized that while Twinstar had a valid ground for termination, it failed to adhere to due process requirements, violating the "two-notice rule" mandated by the Labor Code. Consequently, while no constructive dismissal occurred, Dela Torre was entitled to nominal damages for the procedural due process violation. The Court highlighted the need for proper notice and a fair opportunity for the employee to defend themselves in termination cases.
Nominal Damages and Quitclaim
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Background of the Case
- The case involves a Petition for Review on Certiorari filed by Jose R. Dela Torre (petitioner) against Twinstar Professional Protective Services, Inc. (respondent).
- The petition challenges the September 3, 2015 Decision and the February 11, 2016 Resolution of the Court of Appeals (CA) which found that the petitioner was not illegally dismissed from his employment.
- Petitioner was employed by Twinstar as a security guard in October 1988 and was deployed at Las Haciendas in Tarlac City, receiving a daily wage of P240.00.
Factual Background
- In January 2011, petitioner sought assistance from Mr. Tulfo to address underpayment of his salaries.
- On January 24, 2011, he was directed to Twinstar's office where he was placed on floating status, which lasted over six months.
- On August 23, 2011, petitioner filed a complaint for illegal dismissal and non-payment of salaries and benefits, later amending the complaint to focus on illegal dismissal and separation pay.
- Twinstar failed to appear at multiple mandatory conferences, leading the Labor Arbiter (LA) to reset submission dates for position papers.
Ruling of the Labor Arbiter
- The LA ruled in favor of the petitioner, determining he was constructively dismissed and entitled to backwages and separation pay.
- The LA ordered Twinstar to pay petitioner a total of Php 276,225.83.
Appeal to the National Labor Relations Commission (NLRC)
- Twinstar appealed, admitting to hiring the petitioner but alleging he went AWOL starting January 21, 2011.
- Twinstar claimed to have sent multiple notices to petitioner to return to work, which he ignored.
- The NLRC granted Twinstar's appeal, reversing the LA's decision, and ruled