Case Summary (G.R. No. 55971)
Background of the Case
Virgilio M. Mantes was employed by Flexo Manufacturing Corporation as a slitting machine operator. He was initially hired in 1966, subsequently terminated in 1974 on the grounds of abandonment but rehired in 1975. On April 18, 1977, Mantes was unable to report for his night shift due to influenza, and he informed his supervisors through a handwritten note delivered by a colleague.
Events Leading to Termination
Upon his recovery, Mantes presented a medical certificate to his employer to justify his absence. He was denied the required excuse slip to resume work, leading to his absence beyond April 18. On May 20, 1977, a clearance application for his termination was sent out by the petitioner, citing abandonment. Mantes subsequently filed a complaint for illegal dismissal on May 25, 1977.
Labor Arbiter's Decision
The Labor Arbiter, Ricarte T. Soriano, ruled in favor of the petitioner on May 23, 1978, granting clearance to terminate Mantes. The decision was appealed by Mantes to the NLRC.
NLRC's Ruling
On October 17, 1980, the NLRC reversed the Labor Arbiter's decision, ordering Mantes' reinstatement with backwages. The NLRC found that Mantes had provided sufficient proof of his illness and had not abandoned his job, emphasizing that his absence was justified.
Grounds of Petitioner's Appeal
Flexo Manufacturing Corporation filed a petition, contending that the NLRC’s decision was marred by grave abuse of discretion, particularly highlighting:
- Lack of notification regarding the notice of appeal, which allegedly violated due process.
- Questioning the timeliness of Mantes' appeal to the NLRC.
- Contesting the basis for NLRC’s award of reinstatement and backwages.
Due Process and Notification Issues
The Supreme Court found that evidence indicated that Mantes' notice of appeal was properly served to Flexo’s counsel, thus countering claims of lack of notification. This service, backed by registry receipts, confirmed that the procedural requirements were fulfilled.
Appeal Timeliness
The NLRC's assessment of the timeliness of Mantes' appeal was upheld, as the notice of appeal was within the appropriate timeframe. The Court highlighted that dismissing the appeal for not serving a copy, if procedural lapses were present, would violate labor rights and constitutional protections.
Interpretation of Abandonment
The Court clarified that for abandonment to justify termination, there must be clear, intentional refusal to return to work. In this case, Mantes did not exhibit such intentions as evidenced by his immediate action of filing for reinstatement upon his dismissal.
Final Decision on Re
...continue readingCase Syllabus (G.R. No. 55971)
Background of the Case
- This case involves a petition for Certiorari filed by Flexo Manufacturing Corporation against the National Labor Relations Commission (NLRC) and Virgilio M. Mantes, stemming from a decision dated October 17, 1980.
- The NLRC ordered the reinstatement of Mantes to his former or equivalent position with full back wages from April 25, 1977, until reinstatement, without loss of seniority rights.
Parties Involved
- Petitioner: Flexo Manufacturing Corporation, a company engaged in the manufacture and printing of packaging materials.
- Respondent: Virgilio M. Mantes, employed by Flexo as a slitting machine operator from 1966 until his termination on March 8, 1974, and subsequently rehired on December 20, 1975.
Termination of Employment
- Mantes was terminated on March 8, 1974, on grounds of abandonment.
- He was rehired in December 1975 and worked until his illness led to an absence on April 18, 1977, which he communicated to management through a handwritten note delivered by a co-worker, Cristeno Magrata.
Events Leading to the Dispute
- Mantes failed to report for work due to influenza from April 18 to April 23, 1977, and provided a medical certificate upon his return.
- Flexo Manufacturing Corporation required an excuse slip from the Personnel and Production Managers, which Mantes was denied despite presenting his medical documentation.
- Mantes was subsequently informed via a clearance application th