Case Summary (G.R. No. 110930)
Background Facts
Orlando Ondon actively campaigned for actual land distribution after a meeting conducted by the Department of Agrarian Reform on February 8, 1992. Tensions escalated when he led a walkout on February 9, 1992, protesting against the management's insistence that workers from a different hacienda be included in a referendum. Subsequently, he was barred from reporting to work, leading to a conversation with Arturo Ledesma on February 18, during which Ledesma stated he no longer wanted Ondon employed due to perceived disloyalty. Ondon filed a complaint for illegal dismissal, underpayment of wages, and non-payment of entitlements on February 27, 1992.
Labor Arbiter Decision
The Labor Arbiter's initial ruling on November 3, 1992, concluded that Ondon was not dismissed but rather given a new assignment, and his refusal to accept this assignment constituted abandonment of work. The Arbiter justified the reassignment as reasonable, citing a breach of trust due to Ondon's opposing stance to management. The Arbiter denied the claims for overtime and night shift premium but awarded service incentive leave and salary differential payments.
NLRC Ruling
Upon appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, declaring that Ondon was unlawfully dismissed. The NLRC found that the petitioners could not adequately counter Ondon’s assertion of dismissal, particularly given Ledesma's failure to provide an affidavit to contest the claim. The NLRC recognized the reassignment from security guard to laborer as a demotion, amounting to constructive dismissal, thus invalidating the employers' claim of good faith in the transfer. Citing the strained relationship, the NLRC opted for separation pay rather than reinstatement and required the payment of back wages and increased service leave compensation.
Petition for Certiorari
The petitioners contended that the NLRC committed grave abuse of discretion in reversing the Labor Arbiter's findings and awarding excessive back wages. The NLRC emphasized that while employers have the right to transfer employees for the efficient operation of business, such rights are limited if exercised in bad faith or for discriminatory reasons, particularly in relation to union activities.
Supreme Court Analysis
The Supreme Court ruled that the NLRC did not exhibit grave abuse of discretion. It applied established jurispr
...continue readingCase Syllabus (G.R. No. 110930)
I. Case Overview
- This case revolves around a petition for certiorari under Rule 65 of the Revised Rules of Court aimed at setting aside the decision of the National Labor Relations Commission (NLRC) concerning the illegal dismissal claim of Orlando Ondon, a security guard employed by Oscar Ledesma and Company.
- The decision from the NLRC was made in Case No. V-0340-92, with a subsequent resolution on June 14, 1993, which denied the petitioners' motion for reconsideration.
II. Background Facts
- Orlando Ondon was employed as a security guard in 1984 at Hacienda Teresa, located in Barangay Alicante, E.B. Magalona, Negros Occidental, managed by Arturo Ledesma.
- The hacienda was under the Comprehensive Agrarian Reform Program (CARP), and on February 8, 1992, a meeting was held by the Department of Agrarian Reform to discuss options for the workers regarding land distribution.
- Following the meeting, Ondon campaigned for actual land distribution while the petitioners favored a stock distribution plan.
- This conflict escalated when, on February 9, 1992, Ondon led a walkout after the petitioners insisted that workers from another hacienda be allowed to vote in the referendum.
- Subsequently, Ondon was prevented from reporting for work and was told by the hacienda administrator to wait for Ledesma.
- On February 18, 1992, Ledesma informed Ondon that he no longer wanted him to work due to concerns over Ondon's loyalty to the workers.
III. Legal Proceedings
- Ondon filed a complaint for illegal dismissal, underpayment of wages,