Case Summary (G.R. No. 225595)
Description of Employment and Circumstances of Dismissal
Tapia was employed as a pharmacist with GA2, with a monthly salary of PHP 16,000. His duties initially involved direct pharmacy operations, but later expanded to include supervisory roles across various branches. On June 11, 2015, after requesting to be excused from work due to illness and a scheduling conflict related to the company car, Tapia faced a verbal altercation with Saldanha. This incident culminated in Saldanha allegedly ordering Tapia to resign or to go home and not return.
Procedural History Leading to Labor Arbiter's Decision
Following this incident, Tapia filed a complaint for illegal dismissal and additional money claims through the Single-Entry Approach. After failing to reach a settlement, he escalated the matter into a formal complaint, initially claiming constructive dismissal, which he later amended to illegal dismissal. The Labor Arbiter dismissed his complaint, finding insufficient proof of arbitrary dismissal, favoring GA2’s contention that Tapia had voluntarily left his position.
National Labor Relations Commission (NLRC) Findings
The NLRC reversed the Labor Arbiter's decision, finding that Tapia had been illegally dismissed. It highlighted several critical points: Tapia's coherent recollection of events, the unsubstantiated nature of GA2's allegations against him, and the lack of evidence regarding his supposed probationary status. The NLRC ordered GA2 to pay Tapia separation pay and backwages, denying all other claims.
Court of Appeals' Ruling
The Court of Appeals partially granted GA2's petition, ordering Tapia's reinstatement without backwages. It concluded that Tapia's allegations were not sufficiently substantiated and also questioned his claims related to his dismissal. The court found both parties' accounts regarding the dismissal to lack definitive evidence, ultimately ruling that Tapia failed to sufficiently prove he was dismissed from his employment.
Present Petition for Review
In his petition for review, Tapia contends that the ruling of the Court of Appeals should be overturned, emphasizing the nature of the verbal order from Saldanha as constituting dismissal. Tapia argues that the actions of Saldanha indicated his termination and that he acted promptly in filing the complaint, which negated claims of abandonment.
Supreme Court's Ruling
The Supreme Court reinstated the NLRC's ruling, emphasizing its role in resolving factual inconsistencies among earlier rulings from the Labor Arbiter, NLRC, and the Court of Appeals. The Court clarified that sufficient evidence was presented by Tapia to support his claim of dismissal, particularly noting Saldanha's authoritative verbal order not to report back to work as a clear expr
...continue readingCase Syllabus (G.R. No. 225595)
Background of the Case
- Petitioner Joel A. Tapia filed a petition to contest the Court of Appeals' decision that ordered his reinstatement without backwages and the subsequent resolution denying his motion for reconsideration.
- Tapia was employed as a pharmacist at GA2 Pharmaceutical, Inc. from July 2013, with a monthly salary of P16,000.00.
- His responsibilities included monitoring drugstore operations and overseeing product delivery and sales collection.
- On June 11, 2015, after requesting to be excused from a delivery task due to illness and vehicle restrictions, Tapia was scolded by General Manager Lancy Vijay Saldanha, who ordered him to draft a resignation letter.
- Tapia refused to sign the resignation letter and was told by Saldanha to go home and not return, prompting him to file a complaint for illegal dismissal.
Procedural History
- Tapia initially filed a complaint for illegal dismissal through the Single-Entry Approach (SEnA) on June 15, 2015, followed by a formal complaint on July 24, 2015.
- GA2 contended that Tapia was a probationary employee hired on March 25, 2015, and claimed he was dismissed due to poor performance and refusal to work.
- The Labor Arbiter dismissed Tapia's complaint for lack of merit on January 29, 2016, but the National Labor Relations Commission (NLRC) reversed this ruling on June 30, 2016, declaring Tapia was illegally dismissed and entitled to separation pay and backwages.
Ruling of the Court of Appeals
- The Court of Appeals partially granted GA2's petition for certiorari on July 12, 2017, ordering Tapia's reinstatement