Case Summary (G.R. No. 214294)
Petitioner
JR Hauling Services engaged respondents to transport live broilers from farms in Pangasinan, Tarlac, Batangas, Bulacan, Zambales, or La Union to processing plants in Hermosa, Bataan, issuing job orders and paying P300.00 per trip (two trips per day expected).
Respondents
Former drivers/helpers who claim they averaged one trip per day (P300.00), were not paid 13th month pay, holiday/rest-day premiums, or Service Incentive Leave (SIL) pay, and were summarily dismissed on April 3, 2011 without notice or hearing.
Key Dates
• Employment commenced between October 2003 and August 2010
• Labor Arbiter Decision: December 9, 2011
• NLRC Decision: August 28, 2012; Resolution denying reconsideration: November 15, 2012
• Court of Appeals Decision: September 5, 2014
• Supreme Court Decision: September 30, 2020
Applicable Law
• 1987 Philippine Constitution (labor rights)
• Labor Code of the Philippines, Article 297 (serious misconduct; breach of trust; commission of crime)
• NLRC Rules of Procedure (suppl. by Rules of Court Rule 8, Sec. 11)
• Wage Order No. RBIII-15 (minimum wage P308/day)
Factual Predicate
Respondents hauled broilers per job orders, replaced dead birds with extras from farms, and allegedly incurred shortages of 371 and 377 broilers in February and March 2011. Petitioners discovered unauthorized sales of excess broilers and broiler crates in Concepcion, Tarlac, and relied on an unsigned summary of shortages and notarized affidavits from manager, helpers, and co-employees to justify dismissal for serious misconduct, fraud, and breach of trust.
Labor Arbiter Ruling
The Labor Arbiter found dismissal illegal for lack of just cause and procedural due process: the summary of shortages was unauthenticated; affidavits were hearsay; respondents were field personnel not entitled to certain statutory benefits; ordered reinstatement, backwages, salary differentials, and attorney’s fees.
NLRC Ruling
The NLRC reversed the Labor Arbiter, holding that the affidavits (admissions against interest) and documentary evidence adequately proved loss of trust and confidence as just cause under Article 297(c). It also deemed respondents estopped from invoking due process, dismissed their complaint, and denied monetary claims.
Court of Appeals Ruling
The Court of Appeals granted certiorari, set aside the NLRC Decision for lack of substantial evidence: the unauthenticated summary and uncorroborated affidavits failed to show respondents’ culpability; reinstated the Labor Arbiter Decision ordering reinstatement and backwages.
Issues
- Whether substantial evidence supported respondents’ dismissal for just cause.
- Whether respondents were entitled to salary differentials.
- Whether procedural due process in dismissal was observed.
Standard of Review and Evidentiary Threshold
The Supreme Court may reconcile conflicting findings of the Labor Arbiter, NLRC, and CA. In labor cases, the required quantum is substantial evidence—relevant evidence a reasonable mind accepts to support a conclusion. Technical rules on hearsay do not strictly apply; notarized affidavits enjoy presumptions of regularity and due execution unless rebutted by clear, convincing proof.
Supreme Court Analysis – Just Cause
• The unsigned, uncorroborated summary of shortages lacked authenticity and failed to link respondents to the missing broilers.
• Notarized affidavits of co-employees, manager, and helpers sufficiently established respondents’ participation in unauthorized sales of excess broilers and crates—acts of dishonesty, breach of trust, and serious misconduct.
• Drivers/helpers, though not supervisory, handled employer property and were entrusted with its safe delivery; their misconduct breached the trust essential to their work.
• Dismissal was justified under Article 297(a), (c), and (d) of the Labor Code.
Supreme Court Analysis – Procedural Due Process
• Petitioners conceded no w
Case Syllabus (G.R. No. 214294)
Case Title and Citation
- G.R. No. 214294, September 30, 2020
- JR Hauling Services and Oscar Mapue, Petitioners, vs. Gavino L. Solamo, Ramil Jerusalem, Armando Parungao, Rafael Caparos, Jr., Noriel Solamo, Alfredo Salangsang, Mark Parungao and Dean V. Calvo, Respondents
- Second Division; Perlas-Bernabe, Senior Associate Justice (Chairperson)
Nature of the Case
- Petition for Review on Certiorari under Rule 45 of the Rules of Court
- Challenge to the Court of Appeals’ reversal of NLRC’s finding of just cause for dismissal
- Core questions: validity of dismissal for loss of trust and confidence; entitlement to salary differentials
Factual Antecedents
- Respondents employed as drivers/helpers by JR Hauling Services (domestic hauling corporation) from 2003–2010
- Paid ₱300 per trip, tasked to transport live broiler chickens and crates from farms (Pangasinan, Tarlac, Batangas, Bulacan, Zambales, La Union) to clients’ processing plant in Hermosa, Bataan
- Required two trips daily (₱600/day), but realistically averaged one trip (₱300/day) due to distance
- Alleged non-payment of 13th month pay, holiday pay, rest day pay, SIL pay
- On April 3, 2011, management displayed respondents’ photos at gate and barred entry—purported summary dismissal without notice or hearing
Petitioners’ Defense
- Alleged broiler shortages: 371 pieces in February 2011, 377 pieces in March 2011 (total 748)
- Presented unsigned “Summary of Short Broilers Delivery” from SMFI for Feb–Mar 2011
- Discovery of unauthorized sale of excess broilers and crates in Concepcion, Tarlac, committed by respondents without company consent
- Testimonial evidence: affidavits of Mapue (manager), Pedro (helper), co-employees Acoba, Enriquez, Moratin, Fuentes, Espares, Sanico
- Grounds for dismissal: serious misconduct, fraud, willful breach of trust and confidence; contention that field personnel paid by results not entitled to monetary claims
Labor Arbiter’s Decision (December 9, 2011)
- Found dismissal illegal for lack of just cause and absence of due process (no notice, no hearing)
- Declared respondents illegally dismissed; ordered reinstatement with full backwages and 10% attorney’s fees
- Dismissed claims for 13th month pay, holiday pay, rest day pay, premium pay, SIL due to field personnel status
- Admitted petitioners’ evidence inadmissible: unsigned summary not authenticated; affidavits hearsay and self-serving
NLRC Decision (August 28, 2012) and Resolution (November 15, 2012)
- Granted petitioners’ appeal; reversed and set aside Labor Arbiter; dismissed complaint for lack of merit
- Held respondents validly dismissed for loss of trust and confidence (serious misconduct, fraud) based on affidavits and summary of shortages
- Affidavits of co-employees and manager taken as voluntary admissions against interest
- Respondents estopped from invoking lack of due process due to filing of illegal dismissal complaint before ter