Case Summary (G.R. No. 222289)
Factual Background
East Cam Tech Corporation, a manufacturer of bags, hired respondents as sewers in May 2002. After an illegal dismissal complaint led to their reinstatement, they were reassigned to a less favorable work environment with worn-out machines and faced unrealistic production quotas. They alleged that the Department of Labor and Employment did not sanction these quotas and that they were unfairly targeted to meet an unreasonable production demand.
Events Leading to Dismissal
On January 12, 2010, the respondents were charged with negligence for failing to meet these production quotas, despite being told there was no need to respond to the charges. They were eventually dismissed on February 27, 2010, prompting the filing of a new illegal dismissal complaint against East Cam and its management.
East Cam's Defense
East Cam defended its actions by referencing a Time and Motion Study (TMS) aimed at enhancing productivity, asserting that failure to meet the production standards constituted negligence. The company stated that the respondents’ inability to fulfill the set quotas justified their dismissal, as the employees had received previous warnings.
Labor Tribunal's Decisions
The Executive Labor Arbiter dismissed the respondents' initial complaint, asserting East Cam's right to assign work and discipline employees. The NLRC upheld this decision, citing habitual neglect of duty as the basis for dismissal due to the respondents' repeated failure to meet quotas.
Court of Appeals' Ruling
On appeal, the Court of Appeals overturned the NLRC's decision, determining that the respondents had no prior record of neglect and had strived to meet an unachievable quota. It emphasized that management's setting of quotas must be made in good faith, and the evidence suggested that the respondents' dismissal was not justified.
Supreme Court's Ruling
The Supreme Court affirmed the Court of Appeals' ruling, highlighting several key points:
- Evidence of Negligence: The risks involved in ascribing habitual negligence to the respondents were unfounded, as substantial evidence indicated they were unfairly subjected to an ambiguous production assessment after being transferred from their previous roles.
- Reassessment of Evidence: The Court noted the discrepancies between the findings of the ELA, NLRC, and the CA, which warranted examination of the factual circumstances presented.
- Management Prerogative: While the employer has the discretion to se
Case Syllabus (G.R. No. 222289)
The Case
- This petition for review on certiorari under Rule 45 contests the May 29, 2015 Decision and December 11, 2015 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 123946.
- The CA nullified the October 11, 2011 Decision of the National Labor Relations Commission (NLRC) and mandated the reinstatement of respondents, along with payment of backwages and other monetary claims.
The Facts
- Petitioner East Cam Tech Corporation (East Cam) is engaged in bag manufacturing and hired respondents Fernandez, Delos Santos, Trinidad, and Manalansan as sewers in May 2002.
- Respondents had previously filed an illegal dismissal complaint against East Cam, leading to their reinstatement and reassignment to the sewing line of the sample department.
- Upon reassignment, respondents observed that they were given old, worn-out machines and were stationed far from the sample room where specialized machines were located.
- They felt singled out, as they were the only employees required to meet a production quota and submit hourly reports, which they alleged were not approved by the Department of Labor and Employment (DOLE).
- On January 12, 2010, East Cam charged them with negligence of duty for failing to comply with the production quota.
- They were informed by their supervisor that there was no need to respond to this charge, as he would address the issue.
- On February 27, 2010, they were dismissed for failing to respond to the charge.
The Labor Tribunals' Decisions
- The respondent