Case Summary (G.R. No. 194575)
Employment Background
Gabriel was employed by Petron starting May 1987 and was promoted to QMS Coordinator on October 18, 2004. Despite this promotion, he did not receive a corresponding salary increase or recognition of his new role. The situation escalated following a complaint letter lodged against him by Charina Quiwa, the goddaughter of Trio, who was the General Manager of Petron's Refining Division.
Allegations and Administrative Actions
In light of Quiwa's complaint, which Gabriel denied, he claimed that the management subjected him to harassment and subsequently interpreted his actions as violations of company rules. This culminated in Gabriel filing a complaint for constructive dismissal. Petron asserted that Gabriel's re-assignment was not a promotion but part of a company reorganization and that his subsequent actions, including the use of company resources for personal business, warranted an investigation.
Labor Arbiter's Decision
The labor arbiter ruled in favor of Gabriel, stating that his role as QMS Coordinator constituted a supervisory position and that the complaints against him were baseless, attributing them instead to malice stemming from Quiwa’s grievance. Consequently, Gabriel was awarded back wages, separation pay, and damages.
NLRC Decision
However, on April 27, 2009, the National Labor Relations Commission (NLRC) reversed the labor arbiter’s decision, dismissing Gabriel’s complaint. The NLRC found that Gabriel's reassignment was a lateral transfer without promotion and that there was no substantial evidence to support his claims of harassment.
Court of Appeals Proceedings
Gabriel sought to appeal the NLRC decision and initially filed a motion for reconsideration, which was denied on May 14, 2010. He then filed a petition for certiorari with the Court of Appeals (CA) but missed the deadline for filing due to logistical challenges in securing authentication from the Philippine Consular Office. The CA dismissed his motion for extension, citing strict procedural rules.
Supreme Court Ruling
Gabriel brought his case to the Supreme Court, arguing that the CA committed an error in denying his motion for extension of time to file his petition. However, the Court held that certiorari is not a substitute for appeal and that the scope of its review is limited to
...continue readingCase Syllabus (G.R. No. 194575)
Case Background and Overview
- This case involves a petition for review on certiorari filed by Angelito N. Gabriel against Petron Corporation and its officials, stemming from a labor dispute regarding his employment status and subsequent dismissal.
- The decision was rendered by the Supreme Court on April 11, 2018, under G.R. No. 194575.
Employment History of Angelito N. Gabriel
- Gabriel was employed by Petron Corporation as a Maintenance Technician starting in May 1987.
- Due to his dedication and pursuit of further education, he was promoted to Quality Management Systems (QMS) Coordinator on October 18, 2004.
- Despite his new position, Gabriel did not receive a salary increase or additional benefits, which he attributed to a complaint lodged against him.
The Complaint and Allegations
- The complaint against Gabriel was initiated by Charina Quiwa, who is related to Alfred A. Trio, the General Manager of Petron’s Refining Division.
- Gabriel was accused of harassment, which he denied, stating that he had resolved the misunderstanding with Quiwa privately.
- Following the complaint, Gabriel reported experiencing harassment from Petron’s management, leading him to claim constructive dismissal.
Management's Defense
- Petron management characterized Gabriel's role as QMS Coordinator as a lateral transfer rather than a promotion, citing no increase in rank or salary.
- They contended that subsequent actions taken against Gabriel were part of an ongoing investigation regardin