Case Summary (G.R. No. 150454)
Factual Background
Respondent Paulina Cabanban was employed by GSP Manufacturing Corporation as a sewer from February 7, 1985, until her alleged termination on March 1, 1992. Following her dismissal, Cabanban filed a complaint against the petitioners on June 16, 1992, asserting illegal dismissal and non-payment of holiday pay, service incentive leave pay, and 13th month pay. She contended that she was terminated for failing to persuade her daughter not to work for Sylvia Santos Company, a competitor of GSP. In defense, the petitioners argued that Cabanban abandoned her job on March 14, 1992, a claim they reported to the Department of Labor and Employment on May 15, 1992.
Initial Labor Arbiter's Decision
On May 7, 1993, Labor Arbiter Melquiades Sol D. del Rosario ruled in favor of Cabanban, finding the petitioners guilty of illegal dismissal. The petitioners subsequently appealed this decision to the NLRC. In a resolution dated August 10, 1995, the NLRC confirmed the labor arbiter's ruling in its entirety.
Petitioners' Arguments on Appeal
In their petition for review on certiorari, the petitioners contested the factual findings of the Court of Appeals, which had affirmed the labor arbiter's decision. They specifically challenged the assessment of the evidence, arguing that the conclusions were based on statements made only in the respondent's affidavit and were made arbitrarily.
Court’s Ruling on Factual Findings
The Supreme Court stated that the factual findings of the NLRC are binding, particularly when aligned with those of the labor arbiter, provided that there is no unfairness or arbitrariness in the evaluation of evidence. After examining the records, the Court found no proof of arbitrariness and reiterated principles regarding abandonment of employment.
Abandonment and Employment Duties
The Court clarified that abandonment as a just cause for dismissal necessitates a clear and unjustified refusal by the employee to fulfill their job responsibilities. It noted that mere absence, especially without a formal notice to return to work from the employer, does not constitute abandonment. It also established that the act of filing a complaint for illegal dismissal is incompatible with a claim of abandonment, as it demonstrates the employee's intent to return to work.
Timeliness of Filing the Complaint
The Supreme Court dismi
...continue readingCase Syllabus (G.R. No. 150454)
Case Overview
- This case involves a petition for review on certiorari stemming from a decision and resolution of the Court of Appeals, regarding issues of illegal dismissal.
- Petitioners include GSP Manufacturing Corporation and Charo Apacible, while the respondent is Paulina Cabanban.
Factual Background
- Paulina Cabanban was employed as a sewer by GSP Manufacturing Corporation from February 7, 1985, until her alleged termination on March 1, 1992.
- On June 16, 1992, Cabanban filed a complaint with the National Labor Relations Commission (NLRC) alleging illegal dismissal, non-payment of holiday pay, service incentive leave pay, and 13th month pay.
- Cabanban claimed her termination was due to her failure to dissuade her daughter from working at a competitor, Sylvia Santos Company.
- Petitioners contended that Cabanban had abandoned her job on March 14, 1992, and that they reported this abandonment to the Department of Labor and Employment on May 15, 1992.
Procedural History
- Labor Arbiter Melquiades Sol D. del Rosario found the petitioners guilty of illegal dismissal on May 7, 1993.
- Petitioners appealed the decision to the NLRC, which affirmed the labor arbiter's ruling in full on A