Case Summary (G.R. No. 189851)
Background Facts
The respondents were employed as production workers between 1997 and 1998. In 2005, Intec claimed to be experiencing a lack of job orders, leading to a reduction in their working days. However, the respondents contended that during this period, Intec hired approximately 188 contractual employees to perform the same tasks they were regularly doing. This reduction in working days ultimately led to a declaration of termination by the respondents on May 17, 2006, prompting them to file a complaint for illegal dismissal.
Labor Arbiter and NLRC Findings
On December 14, 2007, the Labor Arbiter ruled that the respondents were illegally dismissed and ordered Intec to pay separation pay and back wages. This decision was grounded on evidence that Intec replaced the respondents with casual employees. Conversely, the NLRC subsequently overturned this ruling, contending that Intec’s financial woes justified the reduction of working days and stated that the employees had not been dismissed.
Court of Appeals Decision
The Court of Appeals, on April 22, 2009, reinstated the Labor Arbiter's decision, finding that the respondents were indeed constructively dismissed. The Court ruled that the actions by Intec constituted a significant alteration of their employment terms, establishing grounds for constructive dismissal.
Petition for Certiorari
Intec subsequently filed a Petition for Certiorari, alleging various grounds of grave abuse of discretion by the Court of Appeals. These included the Court’s inconsistency in handling the private respondents’ motion for reconsideration, the disregard for the NLRC's factual findings, and the claim regarding the reliability of financial statements presented by Intec.
Management Prerogative and Good Faith
The Court underscored that management has the right to regulate employment conditions, including work hours. However, this prerogative must be exercised in good faith and with due regard to employees’ rights. Intec had the burden to demonstrate that the reduction in work days was justified and executed in good faith.
Financial Claims and Evidence
Intec presented financial statements to substantiate its claims of suffering financial losses. However, the Court noted inconsistencies and questioned the relevance of these documents, particularly as Intec appeared to have recorded a net income in 2006 contrary to its claims of financial distress.
Constructive Dismissal and Abandonment
The Court acknowledged that constructive dismissal occurs when employees are forced to abandon their positions due to significant changes imposed by the employer. Intec’s assertion of abandonment was refuted, as the respondents' filing of a complaint for illegal dismissal negated any claim of willful abandonment
...continue readingCase Syllabus (G.R. No. 189851)
Case Background
- Petitioners: Intec Cebu Inc., Akihiko Kambayashi, and Wataru Sato.
- Respondents: Rowena Reyes, Rowena R. Odiong, Hydee P. Ayuda, Teresita C. Berido, Cristina S. Labapiz, Gemma T. Jumao-as, Sigmaringa B. Barolo, Ligaya B. Anadon, Donaline Dela Torre, Joy P. Lomod, Jacqueline A. Flores, Susan T. Aliao, Analyn P. Aballe, Caroline A. Labatos, Lenith F. Romano, Leonila B. Flores, Cecilia G. Papellero, Agnes C. Casio, Violeta O. Matchete, Candida I. Crujido, Claudia B. Cutamora, Rosalie R. Policios, Genelyn C. MuAez, Alome Migue, Elsie Alcos, Lydialyn B. Godinez, Myrna S. Logaos, and others.
- Case Reference: G.R. No. 189851, decided on June 22, 2016.
- Legal Context: This case involves a petition for certiorari under Rule 65 of the Rules of Court, contesting the decisions of the Court of Appeals.
Antecedent Facts
- Company Overview: Intec Cebu Inc. is engaged in manufacturing and assembly of mechanical systems and printed circuit boards for consumer electronics.
- Employment History: Respondents were employed as production workers during 1997 and 1998.
- Reduction of Working Days: In 2005, Intec reduced the working days from six to two to four days due to alleged lack of job orders, despite hiring 188 contractual employees to perform tasks that regular employees had previously done.
- Allegation of Termination: On May 17, 2006, respondents claimed they were effectively terminated from employment, leading to a complaint for illegal dismissal.
Labor Arbiter's Decision
- Findings: The Labor Arbiter ruled that respondents were constructively dismissed and ordered Intec to pay separation pay and back wages amounting to P6,967,924.00.
- Dismissal of Other Claims: Other claims were dismissed for lack of evidence.
NLRC Ruling
- Reversal of Arbiter&#