Case Summary (G.R. No. 201396)
Employment Details and Initial Claims
Kondo was assured a monthly salary of P90,000, escalating to P100,000 after six months, alongside various employment benefits, including a service car and financial assistance. Despite receiving positive performance evaluations initially, his subsequent evaluation rating led him to protest amid claims of the discovery of anomalies by the company's headquarters in Japan. Following this, he alleged a series of actions by the company that he deemed discriminatory and punitive, including the withdrawal of his benefits and a transfer to a different department.
Allegations of Constructive Dismissal
Kondo claimed that the removal of his service car and assigned driver, coupled with the reassignment to a new department without relevant experience, amounted to constructive dismissal. He filed a complaint with the National Labor Relations Commission (NLRC) citing illegal dismissal, reduction of benefits, harassment, and discrimination. Respondents contested his claims, stating the benefits were time-bound and not guaranteed past a year, and that his transfer was within management’s prerogative.
Labor Arbiter's Decision
Labor Arbiter Michaela A. Lontoc ruled that Kondo was constructively dismissed due to unjustified benefit withdrawals and the transfer to a department for which he lacked the necessary skills. She ordered reinstatement, back wages, moral and exemplary damages, as well as attorney's fees, ruling that respondents failed to substantiate their claims of a time limitation for the benefit of the service car and the Caltex card he used.
NLRC Appeal and Ruling
Respondents appealed, leading to the NLRC's ruling on May 24, 2010, reversing Lontoc's decision. The NLRC reasoned that there was no constructive dismissal, asserting that Kondo had abandoned his job and that no substantial evidence supported his claims of harassment or unjust transfer.
Court of Appeals Review
Kondo's subsequent petition to the Court of Appeals was denied, reinforcing the NLRC's findings. The Appeals Court noted the distinction between errors of judgment and jurisdiction, emphasizing that Kondo failed to prove any manner of capricious or whimsical exercise of judgment by the NLRC.
Review by the Supreme Court
Upon review, the Supreme Court reiterated that the petitioner carries the burden of proof regarding the facts of his employment termination. It concluded that Kondo did not establish that his resignation was involuntary or
...continue readingCase Syllabus (G.R. No. 201396)
Case Overview
- Petitioner: Yushi Kondo, a Japanese citizen.
- Respondents: Toyota Boshoku (Phils.) Corporation, Mamoru Matsunaga, Kazuki Miura, and Joselito Ledesma.
- Case Reference: G.R. No. 201396, decided on September 11, 2019.
- Key Issue: Constructive dismissal and the burden of proof in claims of illegal dismissal.
Background of the Case
- Yushi Kondo was hired by Toyota Boshoku on September 26, 2007, as Assistant General Manager with an initial salary of PHP 90,000. This was to be increased to PHP 100,000 after six months.
- He was promised various benefits, including a service car, driver, 13th month bonus, and vacation and sick leaves.
- Kondo's tenure included implementing policy changes, initially receiving a "perfect" performance evaluation, which later dropped to slightly above average.
Allegations of Unfair Treatment
- Following the performance evaluation, Kondo faced several punitive actions:
- Assigned an older company car and restricted from using other vehicles.
- Denied access to a Caltex card for gasoline expenses.
- Restricted movement within the office and barred from attending meetings.
Change in Management
- Mamoru Matsunaga succeeded Fuhimiko Ito as President, leading to Kondo's transfer to a new department where he alleged a lack of relevant expertise.
- Kondo's service car and driver were withdrawn, leading him to file a complaint for constructive dismissal.
Respondents' Denial of Allegations
- Toyota Boshoku denied Kondo's claims, asserting:
- The service car and driver were benefi