Case Summary (G.R. No. 238212)
Incident Overview
On Christmas Day, 1984, Lausa, who had been employed since January 1979, reported to the vessel while under the influence of alcohol. His behavior was belligerent, and he challenged officers and crew members to a fight, which prompted Chief Mate Antonio Tendencia Jr. to intervene.
Termination Process
Following the incident, Negros Navigation requested a written explanation from Lausa regarding his conduct. He denied the allegations, asserting that his behavior was provoked. A formal investigation found sufficient evidence of serious misconduct, leading to Lausa's termination effective January 18, 1985.
Legal Proceedings
On March 1, 1985, Lausa filed a complaint for illegal dismissal against his employer. The Executive Labor Arbiter ruled in Lausa’s favor on June 13, 1986, stating the dismissal was without just cause and awarded him separation pay rather than reinstatement, citing a breakdown in the employer-employee relationship.
Appeals and NLRC Decision
Both parties appealed to the National Labor Relations Commission (NLRC), which upheld the Executive Labor Arbiter’s ruling. Negros Navigation argued that the Arbiter erred in accepting Lausa's account, while Lausa contended that he should have been reinstated instead of being awarded separation pay.
Examination of Evidence
The Supreme Court found that the NLRC, along with the Executive Labor Arbiter, had disregarded significant evidence presented by Negros Navigation, including contradicting affidavits from the Chief Mate and crew members that corroborated the misconduct of Lausa. The Court concluded that there were no substantial inconsistencies in the evidence that warranted its rejection.
Misconduct Determination
The Court addressed whether Lausa's actions constituted serious misconduct justifying dismissal. It determined that his intoxicated and aggressive behavior posed a significant threat to passenger safety on a public carrier, thus warranting the dismissal.
Just Cause for Termination
The Court emphasized that under Article 283 of the Labor Code, an e
...continue readingCase Syllabus (G.R. No. 238212)
Case Overview
- Parties Involved:
- Petitioner: Reynaldo Lausa
- Respondents: National Labor Relations Commission (NLRC), Labor Arbiter, Negros Navigation Company, Inc., and its Personnel Officer.
- Case Numbers: G.R. No. 79731 and G.R. No. 80407
- Date of Decision: July 9, 1990
- Jurisdiction: Philippine Supreme Court
- Judgment: The Supreme Court granted the petition of Negros Navigation Company, nullifying the decisions of the NLRC and the Executive Labor Arbiter.
Background of the Case
- Employment Details:
- Reynaldo Lausa was employed by Negros Navigation as a messman since January 1979.
- On Christmas Day, 1984, Lausa was assigned to the M/S "Sta. Maria," which was docked at Iloilo City.
- Incident Description:
- At approximately 5:30 PM on December 25, 1984, Lausa arrived at the ship in a drunken state, with his uniform improperly worn.
- He exhibited belligerent behavior, challenging crew members and passengers to fight, which was witnessed by the Chief Mate, Antonio Tendencia Jr.
- Lausa was later found sleeping in his quarters after disembarking the ship, raising concerns about potential further misconduct.
Events Following the Incident
- Investigation and Termination:
- After reviewing the incident, Negros Navigation requested a written explanation from Lausa regarding his behavior.
- Lausa denied the allegations, claiming a misunderstanding during a marital argument and asserting he was not intoxicated.
- A formal investigation concluded that his behavior constituted serious misconduct, leading to his termination effective January 18, 1985.
Legal Proceedings
- Filing of the Complaint:
- Lausa filed a complaint for illegal dis