Case Summary (G.R. No. 213863)
Facts
Petitioners Floren Hotel and its representatives, Ligaya Chu, Dely Lim, and Jose Chua Lim, sought to annul the decision rendered by the Court of Appeals which had determined that the private respondents—Roderick Calimlim, Ronald Rico, Jun Abalos, Lito Bautista, and Gloria Lopez—had been constructively dismissed from their employment as room boys, a front desk man, and a waitress, respectively. The private respondents began their employment between 1993 and 1995. The issues stemmed from incidents on June 6, 1998, during an inspection where Dely Lim discovered Bautista sleeping on the job and Calimlim and Rico drinking beer in the hotel rooms. Following these incidents, disciplinary measures were taken, and private respondents were eventually suspended.
Labor Arbiter's Decision
The Labor Arbiter ruled that the three respondents—Calimlim, Rico, and Bautista—were not illegally dismissed but had abandoned their work. However, the Arbiter mandated the petitioners to pay the respondents their proportionate 13th month pay and service incentive leave pay along with indemnity to Calimlim and Rico. The Arbiter deemed the demotion and changes in employment status as valid management decisions and found that the procedural requirements for dismissal were not met.
NLRC Ruling
Upon appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, ruling that the private respondents were illegally dismissed and ordered their reinstatement with full back wages and benefits. The NLRC established that petitioners failed to prove abandonment and that Calimlim and Rico had been constructively dismissed due to their demotion and the lack of due process in the disciplinary actions taken against them.
Court of Appeals Decision
Upon further appeal, the Court of Appeals modified the NLRC’s judgment. It recognized Calimlim and Rico's constructive dismissal while affirming that Bautista, Abalos, and Lopez had abandoned their jobs. The court also mandated the hotel to pay all private respondents their proportionate 13th month pay and service incentive leave, as previously computed.
Issues Presented
The Supreme Court faced multiple issues regarding procedural aspects and the determination of whether dismissals had occurred. These included the validity of the Court of Appeals' acceptance of petitioners' appeal and the nature of private respondents' dismissals. The central focus was whether abandonment had occurred legitimately and whether the actions of the petitioners constituted constructive dismissal.
Legal Principles and Findings
The Court determined that the petitioners failed to provide sufficient evidence for their claims of abandonment, as mere absence does not equate to an intent to sever employment. The failure to serve written notices of termination further supported the private respondents' claims of illegal dismissal. The Court clarified that for a dismissal grounded on abandonment, there needs to be evidence of a clear intent to leave employment. The claims of management prerogative regarding the reassignment and demo
...continue readingCase Syllabus (G.R. No. 213863)
Case Overview
- Petitioners, Floren Hotel and its associates, seek to annul the September 10, 2002 Decision of the Court of Appeals regarding the constructive dismissal of private respondents.
- The private respondents, comprising room boys, a front desk man, and a waitress, claimed illegal dismissal and various monetary claims against the petitioners.
- The case revolves around the events leading to the termination of the employees and the alleged failures of the hotel management in adhering to proper dismissal procedures.
Background of the Case
- The private respondents started their employment in 1993, except for Jun A. Abalos, who began in 1995.
- A pivotal incident occurred on June 6, 1998, when petitioner Dely Lim conducted a room inspection and discovered various infractions by the employees, including sleeping on duty and unauthorized use of hotel property.
Incident Leading to Dismissal
- Dely Lim found Lito F. Bautista sleeping in Room 301 and subsequently encountered Roderick A. Calimlim and Ronald T. Rico drinking beer in Room 303.
- Following these findings, Lim issued a memorandum to Bautista detailing several infractions, which Bautista refused to accept.
- All three employees went absent without leave after being confronted about their conduct, prompting the hotel management to serve them suspension notices the following day.
Complaints Filed
- On June 25, 1998, private respondents filed separate complaints for illegal dismissal and monetary claims.
- Calimlim and Rico claimed constructive dismissal, while Bautista stated he was orally dismissed.
- Other private respondents, Abalos a