Case Summary (G.R. No. 193421)
Factual Background
Feliciano C. Libunao, Jr., employed by McMer Corporation, Inc. as a Legal Assistant, was promoted to Head of the Legal Department in January 2000. His employment was marked by conflicts with management, specifically over company policies and practices. Tensions escalated when on July 20, 2007, Libunao felt threatened by Roque's aggressive demeanor, which prompted him to refuse to comply with a summons to Roque's office. Following a police report about the altercation, Libunao did not return to work until July 30, 2007, leading to a memorandum from McMer regarding his absence without official leave.
Procedural History
On August 6, 2007, Libunao filed a complaint alleging unfair labor practices, constructive illegal dismissal, non-payment of 13th month pay, separation pay, and damages against petitioners. A conciliation meeting occurred but failed to resolve the issues, resulting in Libunao being offered separation pay, which he rejected. The Labor Arbiter found no constructive dismissal but awarded Libunao a proportionate 13th month pay and separation pay. Libunao appealed the decision, leading the NLRC to reverse the Labor Arbiter's findings and award him full backwages, separation pay, and damages, asserting that he had indeed been constructively dismissed. The CA upheld the NLRC's decision, prompting the petitioners to seek certiorari from the Supreme Court, alleging errors in the CA's findings.
Legal Analysis
The central issue before the Supreme Court was whether the Court of Appeals (CA) erred in affirming the NLRC's finding of constructive dismissal. The Court noted that while it often refrains from re-evaluating factual findings, conflicting conclusions by the Labor Arbiter, NLRC, and CA warranted a thorough examination. Constructive dismissal is characterized as cessation of work made necessary by unbearable working conditions, effectively compelling the employee to resign.
Findings on Constructive Dismissal
The Court found substantial evidence indicating that Libunao experienced a hostile work environment, primarily due to Roque's aggressive and intimidating behavior on July 20, 2007. The CA properly considered the events leading to Libunao's absence as part of a broader pattern of oppressive management practices that rendered continued employment intolerable.
Evidence Assessment
The Court affirmed the value of both the police blotter documenting Libunao's report and the sworn affidavit provided by Ginalita C. Guiao, which highlighted Roque's threatening demeanor during the incident. The Court emphasized that, while police reports are generally of limited probative value, they gain weight when not effectively contradicted. Guiao's observations established a clear hostile enviro
...continue readingCase Syllabus (G.R. No. 193421)
Case Background
- The case involves a petition for review on certiorari filed under Rule 45 of the Rules of Court.
- Petitioners are McMer Corporation, Inc., Macario D. Roque, Jr. (General Manager), and Cecilia R. Alvestir (President).
- Respondent Feliciano C. Libunao, Jr. was employed as a Legal Assistant and later promoted to Head of the Legal Department with a combined salary of P19,500.00.
- Tensions arose between the private respondent and petitioners due to disagreements over company policies and procedures.
Incident Leading to the Complaint
- On July 10, 2007, the petitioners allegedly made unfounded accusations against other employees, which heightened the rift with Libunao.
- On July 20, 2007, Libunao received a summons from Roque to discuss administrative matters, which made him feel threatened.
- Libunao, fearing for his safety, did not comply and instead informed Alvestir of the situation before leaving work early that day.
- Following this incident, Libunao did not report for work from July 21 to July 30, 2007, due to fears of physical harm.
Disciplinary Actions and Complaints
- McMer Corporation issued a memorandum on July 30, 2007, directing Libunao to explain his absences.
- On August 6, 2007, Libunao filed a complaint against the petitioners for unfair labor practices, constructive illegal dismissal, and non-payment of benefits.
Labor Arbiter's Decision
- The Labor Arbiter ruled on March 12, 2008, that th