Case Summary (G.R. No. 217455)
Background of the Case
The case revolves around a petition for review on certiorari filed by the petitioners, challenging the decision of the Court of Appeals which upheld the ruling of the National Labor Relations Commission (NLRC) regarding Melivo's illegal dismissal claim. Melivo had initiated proceedings after being allegedly dismissed from his position as a room boy at Oyster Plaza Hotel. He sought reinstatement and compensation for unpaid wages and benefits.
Procedural History
On October 22, 2009, Melivo filed a complaint for illegal dismissal against the petitioners. The summons and complaint were served via registered mail, but the petitioners failed to attend scheduled hearings. Eventually, the case was submitted for decision ex parte, leading the Labor Arbiter (LA) to rule in favor of Melivo, declaring his dismissal illegal, given that he had become a regular employee by virtue of the duration of his service.
Labor Arbiter's Decision
The LA ordered Melivo's reinstatement and awarded him back wages, 13th month pay, and attorney's fees. The LA concluded that Melivo’s employment status had transitioned from probationary to regular after his extended service, which necessitated a valid cause for dismissal—something the petitioners failed to provide.
NLRC's Ruling
Upon appeal, the NLRC affirmed the LA's decisions, asserting that the service of summons was valid and that Melivo was not a project employee as the petitioners claimed. The NLRC emphasized the failure to submit a termination report, further reinforcing Melivo's status as a regular employee and concluding that his dismissal lacked just cause.
Court of Appeals' Decision
The Court of Appeals upheld the NLRC's ruling, dismissing the objections of the petitioners regarding service of summons and asserting procedural errors did not invalidate the labor tribunals' jurisdiction. The appellate court found no merit in the arguments posed by the petitioners concerning Melivo's employment status and reaffirmed the findings of illegal dismissal.
Issues Raised by Petitioners
The petitioners contended that (1) they were deprived of due process due to defective summons service; (2) the Court of Appeals erred in finding Melivo was illegally dismissed; and (3) they should not be held solidarily liable for the actions leading to Melivo's alleged illegal dismissal.
Court's Findings on Due Process
The Supreme Court noted that in quasi-judicial contexts, particularly under labor laws, service of summons requires only substantial compliance. The service was undertaken via registered mail and thus, was deemed valid. The burden to prove any irregularity rested on the petitioners, who failed to establish their claims of improper service.
Ruling on Illegal Dismissal
The Court concurred with the NLRC's conclusion that Melivo was a regular employee and that there was no lawful termination of his employment. The petitioners did not present valid justifications for the dismissal nor did they follow the appropriate procedures for ending Melivo’s employment.
Solidary Liability o
...continue readingCase Syllabus (G.R. No. 217455)
Overview of the Case
- The case involves a Petition for Review on Certiorari filed by petitioners Oyster Plaza Hotel, Rolito Go, and Jennifer Ampel against respondent Errol O. Melivo, seeking to reverse the decisions of the Court of Appeals and the National Labor Relations Commission (NLRC) regarding Melivo's alleged illegal dismissal.
- The Supreme Court's decision was rendered on October 5, 2016, under G.R. No. 217455.
Antecedents
- On October 22, 2009, Melivo filed a complaint for illegal dismissal against the petitioners, requesting reinstatement and various monetary claims.
- Summons were served via registered mail on October 26, 2009, but the petitioners failed to appear at the scheduled conciliation/mediation conferences.
- The case progressed to formal hearings, where only Melivo appeared, and he subsequently submitted a position paper detailing his employment history with Oyster Plaza.
- The Labor Arbiter (LA) ruled on April 20, 2010, in favor of Melivo, declaring his dismissal illegal and ordering his reinstatement along with back wages and other monetary awards.
The Labor Arbiter's Ruling
- The LA determined that Melivo had attained regular employment status after six months, thus could only be terminated for a valid cause.
- The LA found no evidence of underpayment but ruled in favor of Melivo regarding his illegal dismissal and ordered reinstatement and payment of back wages and attorney's fees.
NLRC Ruling
- The NLRC affirmed the LA's decision on June 21, 2011, stating that the summons and complaint were validly served and that the petitioners had not pro