Case Summary (G.R. No. 189404)
Factual Antecedents
The petitioners, employed as janitors and leadsmen by Power Master, Inc. and Tri-C General Services, filed a complaint for money claims against the respondents, asserting violations of minimum wage laws, unpaid overtime, holiday pay, premium pay, service incentive leave, and thirteenth-month pay. They claimed to have been coerced into signing blank payroll sheets. Following these allegations, the petitioners amended their complaint to include claims of illegal dismissal after they were allegedly terminated for retaliatory reasons once they filed their claims. The respondents, however, largely abstained from participating in legal proceedings.
Labor Arbiter’s Ruling
On March 15, 2002, the Labor Arbiter ruled partially in favor of the petitioners, awarding them salary differentials, service incentive leave, and thirteenth-month pay. The Labor Arbiter held that the burden of proving payment of claims lay with the employer. However, the requests for backwages, overtime, holiday, and premium pays were denied due to lack of evidence to support claims of unpaid work. Furthermore, it was concluded that the petitioners had not been unlawfully dismissed since there was no evidence of a formal termination.
Proceedings Before the NLRC
Both parties appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC). The petitioners contested the denial of their claims for backwages and other payments, while the respondents alleged that the Labor Arbiter lacked jurisdiction. They provided payroll evidence as proof of payment which the NLRC later prolonged due to claims of procedural due process violations against the respondents. However, the NLRC ruled that the petitioners were dismissed for serious misconduct arising from their non-compliance with company directives.
NLRC Ruling
The NLRC issued a resolution on November 27, 2003, favoring the respondents, stating that they were validly dismissed and that the Labor Arbiter had jurisdiction over the case proceedings. The NLRC ruled that the evidence submitted by the respondents demonstrated compliance with due process in their defense. The absence of the petitioners' signatures in the payrolls was not deemed critical for authenticity, and the case highlighted that several individuals may possess multiple signatures.
The Court of Appeals (CA) Ruling
The CA sustained the NLRC’s decision, arguing that the petitioners were afforded due process. It held that the petitioners had not adequately justified their claims and that they had failed to comply with company policies. The CA also determined that the NLRC had properly admitted the respondents’ evidence on appeal.
The Petition
In their petition, the petitioners argued about the failure of the CA to recognize the NLRC's alleged grave abuse of discretion regarding the acceptance of the respondents' appeal and supplemental documents. They contended that the bond posted by the respondents was invalid, asserting it was not issued by an accredited surety company, and maintained that the NLRC should not have admitted the unverified supplemental appeal.
Respondents’ Position
The respondents countered that the petitioners' arguments regarding the bond's validity were raised for the first time on appeal, and reiterated that the NLRC and CA’s conclusions were justified and supported by evidence.
Issues Presented
- Validation of the CA's decisions concerning the NLRC's manner of processing the appeal
- Examination of the admissibility of the respondents' evidence
- Review of the petitioners' claims regarding illegal dismissal and monetary entitlements
- Dispute over the merits of awarded claims including backwages, salary differentials, and attorney's fees
Court’s Ruling
The Court found that the respondents had not correctly perfected their appeal due to non-compliance with the bonding requirements established by law. The subsequently re
...continue readingCase Syllabus (G.R. No. 189404)
Case Information
- Title: Wilgen Loon, Jerry Arcilla, Albert Pereye, Arnold Pereye, Edgardo Obose, Arnel Malaras, Patrocino Toetin, Evelyn Leonardo, Elmer Glocenda, Rufo Cunamay, Rolando Sajol, Rolando Abucayon, Jennifer Natividad, Maritess Torion, Armando Lonzaga, Rizal Gellido, Evirde Haque, Myrna Vinas, Rodelito Ayala, Winelito Ojel, Renato Rodrego, Nena Abina, Emalyn Oliveros, Louie Ilagan, Joel Entig, Arnel Araneta, Benjamin Cose, Welito Loon, and William Alipao, Petitioners vs. Power Master, Inc., Tri-C General Services, and Spouses Homer and Carina Alumisin, Respondents
- G.R. No.: 189404
- Date: December 11, 2013
- Division: Second Division
- Decision by: Justice Brion
Factual Antecedents
- Employment Context:
- Petitioners were employed as janitors and leadsmen by Power Master, Inc. and Tri-C General Services, assigned to various PLDT offices in Metro Manila.
- Initial Complaint:
- Petitioners filed a complaint for money claims against the respondents, alleging unpaid wages, overtime, holiday pay, service incentive leave, and thirteenth month pay.
- Allegations included being made to sign blank payroll sheets.
- Amendment of Complaint:
- On June 11, 2001, the petitioners amended their complaint to include illegal dismissal, claiming retaliatory actions by the respondents after their initial complaint.
- Respondents' Non-participation:
- The respondents minimally participated in the proceedings, appearing only on a few occasions without submitting a position paper or evidence.
The Labor Arbiter's Ruling
- Decision Date: March 15, 2002
- Partial Favor to Petitioners:
- Awarded salary differential, service incentive leave, and thirteenth month pay.
- The burden of proof for payment of claims rested on the employer.
- Denial of Other Claims:
- Denied claims for backwages, overtime, holiday, and premium pays due to lack of evidence from the petitioners.
- Concluded that the petitioners were not dismissed as they had not shown a notice of termination.
Proceedings before the NLRC
- Appeals:
- Both parties appealed to the National Labor Relations Commission (NLRC).
- Petitioners contested the denial of backwages and other claims, while respondents questioned the jurisdiction and claimed compliance with wage payments.
- Evidence Submission:
- Respondents filed an unverified supplemental appeal with evidence of payments