Case Summary (G.R. No. 206716)
Factual Antecedents
On May 23, 2007, Jordan, together with his co-employees Valentino Galache and Ireneo Esguerra, lodged individual complaints against Grandeur Security for non-payment of wages, leaves, and other benefits. Subsequently, Jordan amended his complaint to include a claim for illegal dismissal, which generated a legal dispute recorded as NLRC-NCR Case No. 05-05003-07. Grandeur Security contended that Jordan was not terminated but merely reassigned and claimed he abandoned work by filing the complaint instead of adhering to the transfer memorandum issued.
Labor Arbiter's Ruling
In a decision dated May 27, 2008, the Labor Arbiter found that Jordan was not illegally dismissed but had simply been reassigned. The Arbiter ordered Jordan's reinstatement and awarded monetary claims to the complainants except for Galache's overtime claim, which lacked evidence. Grandeur Security was mandated to reinstate Jordan without backwages and settle the computed monetary claims amounting to ₱337,228.01.
Proceedings post-May 27, 2008 Decision
Grandeur Security partially appealed the decision but accepted the reinstatement order, claiming it had sent a return-to-work letter to Jordan. The NLRC upheld the Labor Arbiter's decision, which became final and executory by January 20, 2010. Following this, Jordan executed a quitclaim after receiving ₱80,000.00, indicating an unresolved issue regarding his reinstatement.
NLRC Ruling
On February 21, 2011, the NLRC set aside the December 15, 2010 order due to the claimed non-receipt of the return-to-work letter. The NLRC concluded that Jordan was entitled to backwages and separation pay due to Grandeur Security's failure to comply with the reinstatement order, totaling ₱977,255.20 plus attorney's fees.
Court of Appeals Ruling
On April 22, 2013, the Court of Appeals reversed the NLRC's decision, stating that the NLRC had overstepped its jurisdiction by altering a final and executory judgment. The CA asserted that Jordan's claim of non-receipt was a tactic to secure additional monetary awards, and it favored the presumption of lawful delivery of the return letter.
Petition to the Supreme Court
Jordan petitioned the Supreme Court, arguing that the NLRC had not altered the May 27, 2008 decision but addressed the consequences of Grandeur Security's non-compliance with the reinstatement order. Grandeur Security countered by asserting that the NLRC lacked jurisdiction to alter the original decision and that Jordan was not entitled to the claimed benefits as he had not been dismissed.
Issues Presented
The issues outlined include whether an employee retained in employment can be reinstated, the validity of the CA’s ruling nullifying the NLRC’s decisions, the jurisdictional authority of the NLRC over Jordan's appeal, and whether Jordan had waived his right to return to work.
Court
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Case Syllabus (G.R. No. 206716)
Case Background
- The case revolves around the petition for review filed by Ruben C. Jordan challenging the April 22, 2013 decision of the Court of Appeals (CA) in CA-G.R. SP No. 119715.
- Jordan, along with co-employees Valentino Galache and Ireneo Esguerra, filed individual complaints against Grandeur Security for non-payment of wages, holiday pay, service incentive leave, thirteenth month pay, and illegal deductions for insurance premiums.
- Jordan later amended his complaint to include an illegal dismissal claim, asserting that he was terminated from employment.
Factual Antecedents
- On May 23, 2007, the complainants filed their complaints, alleging various unpaid employee benefits.
- Grandeur Security countered by claiming Jordan had not been terminated but merely reassigned and that he abandoned his job by not reporting to the new location.
Labor Arbiter's Ruling
- On May 27, 2008, the Labor Arbiter ruled that Jordan had not been illegally dismissed and ordered his reinstatement, while also awarding monetary claims to the complainants.
- The ruling indicated that Jordan was still employed and had not abandoned his position, despite not reporting to work.
Proceedings After the Labor Arbiter's Decision
- Grandeur Security partially appealed, contesting only the monetary awards but not the reinstatement order.
- The NLRC upheld the Labor Arbiter's decision, which became final and executory on January 20, 2010.
- Jordan executed a quitclaim for P80,000 received from Grandeur Security but stated that reinstatement was still pending.
Subsequent Developments
- On December 15, 2010, the Labor Arbiter closed the case based on the quitclaims, finding that Jordan did not repo