Case Summary (G.R. No. 4277)
Factual Background
On June 16, 1990, Gina G. Castro was employed on a probationary basis. Her employment was terminated on November 10, 1990, citing her failure to meet the requirements outlined in her probationary contract. Subsequently, on November 13, 1990, Castro lodged a complaint for illegal dismissal against the hotel and its general manager at the NLRC. The Labor Arbiter ruled in her favor on December 23, 1991, declaring her dismissal illegal and ordered her reinstatement, along with back wages and other benefits.
NLRC's Decision
The petitioner filed an appeal to the NLRC, contesting the Labor Arbiter's decision. On March 25, 1993, the NLRC overturned the Arbiter's ruling, asserting that Castro had not met the standards for permanent employment and that her dismissal was thus not illegal. However, the NLRC also indicated that Castro should be reinstated on the payroll from the date she filed a motion for execution of the Labor Arbiter’s decision until the NLRC’s pronouncement.
Legal Arguments by the Petitioner
In its certiorari action, the petitioner contended that the NLRC acted with grave abuse of discretion by ordering payroll reinstatement without a writ of execution being issued. The petitioner argued that the motion for execution, which Castro filed, was not resolved, leading to an absence of any formal order necessitating her payroll reinstatement. This situation raised concerns about the principle of "no work, no pay," where salaries cannot be disbursed for periods during which an employee did not perform work.
Private Respondent's Position
Castro argued that the failure to take action on her motion for execution contravened her rights and that the NLRC's resolution should not be declared void. She claimed that the appeal by the hotel was improperly perfected, asserting that the case be remanded for execution of the Labor Arbiter’s decision.
Court's Analysis and Conclusion
The Supreme Court scrutinized whether the NLRC had overstepped its authority in ordering payroll reinstatement. Article 223 of the Labor Code clearly outlines that reinstatement decisions from the Labor Arbiter concerning dismissal are immediately executory pending appeal. However, for reinstatement to take effect, there must be an issuance of a writ of execution, which the Labor Arbiter fai
...continue readingCase Syllabus (G.R. No. 4277)
Case Overview
- This case involves a special civil action for certiorari questioning whether the National Labor Relations Commission (NLRC) acted with grave abuse of discretion in ordering the payroll reinstatement of an employee despite reversing the Labor Arbiter's decision, which had declared there was an illegal dismissal.
- The case was initiated by Gina G. Castro against her employer, Maranaw Hotel Resort Corporation, asserting her rights following her dismissal.
Factual Background
- Gina G. Castro was hired as a guest relations officer on probation for six months by the Century Park Sheraton Hotel on June 16, 1990.
- She was dismissed on November 10, 1990, for allegedly failing to meet the standards set in her probationary employment contract.
- Following her dismissal, Castro filed a complaint for illegal dismissal with the NLRC on November 13, 1990.
Procedural History
- On December 23, 1991, the Labor Arbiter ruled in favor of Castro, declaring her dismissal illegal, ordering her reinstatement, and awarding back wages and other benefits.
- The petitioner, Maranaw Hotel Resort Corporation, received the decision on January 28, 1992, and filed an appeal on February 7, 1992, contesting the Labor Arbiter's findings and the computation of Castro's salary.
- A motion for execution filed by Castro on February 17, 1992, was not acted upon