Case Summary (G.R. No. 210760)
Employment History and Termination
Petitioners began their employment in April 1967, performing maintenance tasks related to the road and water systems of the subdivision. On January 11, 1980, they received notice of their termination due to the purported cessation of the contract between the two realty companies without prior clearance from the Ministry of Labor. Their employment was officially terminated without the requisite legal procedures being followed.
Legal Proceedings Initiated by Petitioners
On February 26, 1980, the petitioners filed a complaint for illegal dismissal, among other claims, at the Arbitration Branch of the National Capital Region, Ministry of Labor. The parties agreed to base the resolution of the case on their position papers without a trial. On December 5, 1980, the Labor Arbiter ruled that the petitioners were illegally dismissed and ordered the private respondents to pay separation pay, allowances, and service incentive leave.
Appeal to the National Labor Relations Commission
Following the Labor Arbiter's decision, private respondents appealed to the National Labor Relations Commission (NLRC) on January 6, 1981, which was beyond the ten-day appeal period mandated by law. However, the NLRC reversed the Labor Arbiter's decision on February 24, 1984, solely on the basis that the petitioners' Position Paper-Affidavit was not verified, ruling it inadmissible as evidence.
Timeliness of the Appeal
The petitioners contended that the appeal by the respondents was time-barred, referencing the timely filing requirements established in jurisprudence, particularly in the case of Vir-Jen Shipping and Marine Services, Inc. The Supreme Court determined that while the Vir-Jen decision established a ten-calendar-day appeal period for future cases, the thirty-day computation in effect at the time of the appeal was applicable, thus allowing for the respondents’ appeal to be considered timely filed.
Verification and Dismissal Legality
The Court found the lack of verification on the petitioners' Position Paper-Affidavit to be a formal defect that did not undermine the validity of the claim. Crucially, the ruling also examined the legality of the petitioners' dismissal under Article 278 of the Labor Code, which requires prior clearance for dismissals of employees with at least a year of service. Since no such clearance was obtained by the respondents before terminating the petitioners, their dismissal was deemed without just cause.
Statutory Benefits Claims
The petitioners' claims for statutory benefits related to Presidential Decrees Nos. 525, 1123, and 1614 were reviewed against the backdrop of the Labor Code's provisions on money claims, which stipulate a three-year limitation. The Court ruled that only claims arising within three years prior to the complaint's filing date were recoverable, marking older claims as prescribed.
Service Incentive Leave Eligibility
Addressing the issue of service incentive leave, the Court noted that the private respondents claimed exemption under the Labor Code for establishments with fewer than ten employees. However, the burden of proof lay with the private respon
...continue readingCase Syllabus (G.R. No. 210760)
Case Overview
- This case involves a dispute between former employees (petitioners) and their employers (respondents) regarding illegal dismissal and other labor claims.
- The case was decided by the Third Division of the Supreme Court of the Philippines on June 30, 1988.
Background of the Case
- Petitioners were employed as maintenance men by the Sun Valley Realty, Inc. in April 1967, responsible for maintaining the roads and water system of the Sun Valley Subdivision.
- On January 11, 1980, they were notified by State Realty and Investment Corporation of their termination effective January 31, 1980, citing the termination of the contract between the two realty companies.
- No application for clearance to terminate employment was filed prior to the dismissal.
Initial Proceedings
- Petitioners filed a complaint for illegal dismissal and other claims on February 26, 1980.
- The case was submitted for decision based on position papers without a formal trial.
- On December 5, 1980, the Labor Arbiter ruled in favor of the petitioners, declaring their dismissal illegal and ordering various compensations.
Appeal to the National Labor Relations Commission (NLRC)
- Respondents appealed the Labor Arbiter's decision on January 6, 1981.
- On February 24, 1984, the NLRC reversed the Labor Arbiter's decision, claiming the petitioners' Position Paper-Affidavit was unverified and thus not legally considered evidence.
Petitioners' Argument
- Petitione