Case Summary (G.R. No. 113337)
Background and Employment Status
The petitioners were employed by Super Mahogany Plywood Corporation, which was acquired by a new ownership group led by Alfredo Roxas on September 1, 1991. Following the acquisition, the petitioners received separation pay and other benefits, which they acknowledged through a Release and Waiver. Subsequently, they applied for new positions under the new management, most of whom were re-employed on a probationary basis with the exception of one petitioner.
Dismissal and Legal Complaints
Two groups of petitioners filed complaints against Super Mahogany Plywood Corporation with the NLRC, alleging various claims including illegal termination, non-payment of wages, and damages. The petitioners contended that despite the change in ownership, they retained their status as regular employees and were entitled to protection against illegal dismissal.
Labor Arbiter's Decision
Labor Arbiter Marissa Macaraig-Guillen ruled in favor of the petitioners, declaring their dismissals illegal and ordering reinstatement to their previous positions along with payment of back wages and other benefits. The Arbiter found that the transfer of ownership did not constitute a cessation of business operations and that the petitioners were effectively still employees of the corporation.
NLRC Appeal and Reversal of Labor Arbiter's Decision
In a subsequent appeal, the NLRC reversed the Labor Arbiter's decision, supporting the argument that the change of ownership was conducted in good faith and did not warrant the same protections under labor laws as a cessation of operations. The NLRC specifically noted that the rights of the newly established management to hire on a probationary basis were upheld.
Supreme Court’s Review and Findings
Upon review, the Supreme Court examined the applicability of precedent cases, particularly distinguishing this case from the Mobil Employees Association case, which related to a complete withdrawal from business. The Court noted ongoing operations under the new ownership and affirmed that the petitioners accepted their severance when they signed the Release and Waiver.
Evaluating the Dismissals for Abandonment
The Court addressed the dismissals of two specific petitioners, Perla Cumpay and Virginia Etic, who were terminated for alleged abandonment. The Court found that the company failed to prove the essential requirements of a lawful dismissal, thus ruling these dismissals illegal.
Ruling Summary
In concluding its ruling, the Supreme Court partially gran
...continue readingCase Syllabus (G.R. No. 113337)
Case Background
- This case is a special civil action for certiorari under Rule 65 of the Rules of Court.
- The petitioners, Ronald Manlimos and others, sought to set aside the resolutions of the National Labor Relations Commission (NLRC) dated 2 August 1993 and 14 October 1993 for alleged grave abuse of discretion.
- The NLRC's resolution of 2 August 1993 reversed the Labor Arbiter's decision, while the resolution of 14 October 1993 denied the motion for reconsideration.
Petitioners and Employment Status
- The petitioners were regular employees of Super Mahogany Plywood Corporation, engaged in various roles such as patchers and taper-graders since the company's formation in 1988.
- Following a change in ownership on 1 September 1991, the petitioners were advised of the ownership transition but continued their employment.
- They were considered terminated by the new management in December 1991, which led to the execution of a Release and Waiver.
Labor Arbiter's Decision
- Labor Arbiter Marissa Macaraig-Guillen ruled in favor of the petitioners on 30 April 1993, declaring their dismissals as invalid.
- Ordered the private respondent to reinstate the petitioners without loss of seniority rights and pay back wages, 13th month pay, service incentive leave pay, and attorney's fees totaling ₱542,150.40.
- The Labor Arbiter concluded that there