Case Summary (G.R. No. 70688)
Timeline of Events
Fuentebella and Llaneza were employed as salesperson and sales supervisor, respectively, but faced issues with their employer related to commission payments. On July 22, 1982, Fuentebella claimed unpaid commissions totaling P2,400.00, which were later approved by management. However, on August 13, 1982, Terre instructed the petitioners to resign without giving reasons, which they complied with. A critical point occurred on August 14, 1982, when Fuentebella collected P6,000.00 from a client but withheld remittance pending resolution of his employment status.
Formal Complaint and Termination
Subsequent to being instructed to submit their resignations, both Fuentebella and Llaneza sought clarification from the company president, Puey, but were met with evasiveness and were denied the opportunity to contest the termination. On August 31 and September 1, 1982, both received letters terminating their employment. This prompted them to file a complaint for illegal dismissal, unpaid wages, commissions, and damages with the National Labor Relations Commission (NLRC).
Employers' Defense
Respondents (HIMARK) contended that the petitioners’ termination was justified based on allegations of dishonesty, specifically regarding the misappropriation of funds represented by the P6,000.00. They argued that this amount was intended for the company, and the failure to remit it was tantamount to a breach of trust.
Labor Arbiter's Decision
On April 29, 1983, the Labor Arbiter ruled in favor of the petitioners, determining that their dismissal was illegal and ordering their reinstatement with full back wages. The Arbiter also acknowledged Fuentebella's entitlement to P12,800.00 in unpaid commissions, deducting the P6,000.00 he had withheld.
NLRC Reversal
Upon appeal, the NLRC reversed the Labor Arbiter's decision on December 10, 1984, determining that the petitioners were dismissed due to legitimate grounds related to dishonesty. They ordered the payment of reduced commissions to Fuentebella and the separation pay to Llaneza. The petitioners subsequently sought reconsideration, which was denied, leading to the filing of the certiorari petition.
Supreme Court's Analysis and Decision
The Supreme Court found merit in the petitioners' argument that the NLRC gravely abused its discretion. It highlighted the lack of due process, noting that the petitioners were not informed of the specific charges against them nor were they afforded an opportunity to defend themselves before dismissal. The absence of a formal investigation further established that the management was committed to terminating their employment without just cause.
Moreover, the Court
...continue readingCase Syllabus (G.R. No. 70688)
Case Overview
- The case involves a petition for certiorari filed by Romulo J. Fuentebella and Jose Angelo Llaneza, former employees of Hi Marketing Corporation (HIMARK), contesting the decision of the National Labor Relations Commission (NLRC) that upheld their dismissal as lawful.
- The petitioners sought to reverse the NLRC's December 10, 1984 decision which contradicted the earlier ruling of Labor Arbiter Raymundo R. Valenzuela from April 29, 1983, declaring their termination illegal.
- The NLRC ordered HIMARK to pay Fuentebella his commission and Llaneza his separation pay, while dismissing the petitioners’ complaints of illegal dismissal.
Background of the Case
- Fuentebella and Llaneza were employed as salesmen at HIMARK, a company engaged in selling high-pressure washers.
- Fuentebella experienced a pay raise due to his performance, while Llaneza was promoted to sales supervisor.
- A dispute arose over unpaid third-party commissions (TPCs), leading to tensions between management and the petitioners.
Events Leading to Dismissal
- On July 22, 1982, Fuentebella claimed unpaid TPCs amounting to P2,400, which management approved.
- Subsequently, a memorandum was issued by Terre instructing salesmen to secure clearance for TPCs and to avoid quoting prices below the company's selling price.
- On August 13, 1982, Terre verbally instructed both petitioners to submit their resignations without providing a cause.
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