Case Summary (G.R. No. 192955)
Factual Antecedents
Etom's complaint, filed on April 15, 2008, alleged that he was improperly dismissed on February 4, 2008, without due process, claiming he was not informed of any violation warranting such action. Contrarily, Aroma Lodging House asserted that it had significant cause for dismissal due to Etom's misconduct and refusal to receive a memo concerning his behavior.
Ruling of the Labor Arbiter
On August 20, 2008, the Labor Arbiter (LA) found Etom's dismissal to be lawful but awarded him back wages, holiday pay, and 13th month pay, citing procedural shortcomings in the termination notice. The LA ordered Aroma to pay him a total of approximately P199,482.80 in various claims but ruled against punitive damages.
Ruling of the National Labor Relations Commission
The National Labor Relations Commission (NLRC) affirmed the LA’s ruling on April 30, 2009, except for punitive damages. The NLRC determined that Etom was underpaid and ordered a corrected salary differential amounting to P166,080.38, considering provisions for facilities provided by the employer.
Ruling of the Court of Appeals
In a reversal of the NLRC decision on January 21, 2010, the Court of Appeals (CA) ruled that Aroma’s motion for reconsideration was timely and discredited Etom’s claims of underpayment based on a prior affidavit he had signed, which acknowledged receipt of wages above the minimum. The CA dismissed claims for 13th month pay and holiday pay, asserting a lack of evidence supporting Etom’s claims.
Petitioner’s Arguments
Etom contended that the CA erred in upholding the timeliness of Aroma’s motion for reconsideration and in favoring his earlier affidavit as an admission against interest. He also argued he wasn’t given the chance to file a responsive pleading to Aroma’s petition for certiorari, which he claimed denied him due process.
Respondent’s Arguments
Aroma maintained that its motion for reconsideration was filed within the legal timeframe, categorically rejecting claims that it failed to pay statutory wages. The respondent emphasized that Etom's earlier affidavit should hold evidentiary weight in determining his wage claims.
Legal Principles and Review Standard
The Supreme Court reiterated that the timeliness of the NLRC decisions would be evaluated under established procedural parameters, affirming
...continue readingCase Syllabus (G.R. No. 192955)
Case Overview
- This case involves a Petition for Review on Certiorari filed by Edilberto P. Etom, Jr. against Aroma Lodging House, challenging the January 21, 2010 decision of the Court of Appeals (CA).
- The CA's decision reversed the April 30, 2009 decision and June 30, 2009 resolution of the National Labor Relations Commission (NLRC), which had awarded Etom unpaid wages, 13th month pay, and holiday pay.
- The CA also denied Etom's motion for reconsideration on July 2, 2010.
Factual Antecedents
- Petitioner Edilberto Etom filed a complaint on April 15, 2008, against Aroma Lodging House for illegal dismissal and money claims.
- He alleged employment as a roomboy since 1997 with a monthly salary of P2,500.00, working long hours from 5:00 a.m. to 11:00 p.m., including holidays.
- Etom claimed that he was barred from reporting to work on February 4, 2008, without prior notice or opportunity to explain any alleged misconduct.
- Respondent Aroma Lodging House contended that Etom was hired in 2000, was compensated above the minimum wage, and received various benefits including free meals and commissions.
- Respondent accused Etom of misconduct, including theft and violent behavior towards coworkers, leading to his termination.
Labor Arbiter's Ruling
- On August 20, 2008, Labor Arbiter Eduardo G. Magno ruled that Etom was legally dismissed but