Case Summary (G.R. No. 173631)
Background of the Case
The respondents, claiming to be employees of the petitioners, asserted that they were subjected to constructive dismissal after being denied regular work since December 1999 and ultimately barred from entering the workplace in May 2000. They alleged underpayment of wages and non-issuance of benefits such as the 13th-month pay, service incentive leave pay, and holiday pay. Conversely, the petitioners claimed that a significant loss in business led them to reduce the working hours of the employees significantly, to three days a week.
Labor Arbiter's Ruling
The labor arbiter sided with the respondents, ruling that they experienced constructive dismissal, ordering petitioners to pay back wages, separation pay, and other claims amounting to P3,132,335.57. However, the arbiter did not grant damages, citing a lack of basis.
Appeal to the NLRC
The arbiter's ruling was received by a security guard on September 24, 2001, and formally delivered to the petitioners on September 25, 2001. The petitioners filed their appeal to the NLRC ten days later, along with a motion to reduce their appeal bond, which they attached documents to support their claims of having paid the withheld benefits. The NLRC concluded that the appeal was time-barred, considering the appeal period commenced from the date the security guard received the arbiter's ruling.
Court of Appeals Decision
The Court of Appeals upheld the NLRC's dismissal of the appeal, reinforcing the necessity of adherence to prescriptive periods for appeals in labor cases and the correct filing amounts for appeal bonds. The petitioners sought reconsideration, raising issues regarding the timing of the receipt and a clerical error in the arbiter's decision regarding the benefits awarded to certain respondents.
Issues Raised
The core issues highlighted in this case include whether the petitioners' appeal to the NLRC was barred by prescription and whether they were liable for the claims made by the respondents concerning constructive dismissal and non-payment of employment benefits.
Ruling on Timeliness of Appeal
The Supreme Court found merit in the petitioners' argument regarding the timing of their appeal. The appeal period should commence from September 25, 2001, when the petitioners received the arbiter's decision, rather than September 24, 2001, when it was received by the security guard. The petitioners' appeal filed on October 5, 2001, was thus deemed timely.
Appeal Bond Considerations
The Court also addressed the validity of the reduced appeal bond, stating that while the Labor Code requires that the bond equate to the awarded amount, there are circumstances where substantial compliance can be accepted. In this context, the petitioners' financial constraints justified their motion to reduce the bond amount.
Determination of Constructive Dismissal
On the issue of constructive dismissal, the Court upheld the labor arbiter's finding, stating that the petitioners did not adequately demonstrate that the respondents abandoned their work. The petitione
...continue readingCase Syllabus (G.R. No. 173631)
Case Overview
- This case involves a review of the rulings of the Court of Appeals regarding the dismissal of a labor case due to late filing and payment of the appeal bond.
- Petitioners are Pasig Cylinder Manufacturing Corporation, A.G. & E Allied Services, and their officers, Manuel Estevanez, Sr. and Virgilio Geronimo, Sr.
- Respondents are a group of 19 former employees who claimed constructive dismissal and sought payment of employment benefits and damages.
Factual Background
- Respondents alleged they were denied regular work since December 1999 and were completely barred from their workplace in May 2000.
- They claimed underpayment of wages and non-payment of mandatory benefits such as 13th month pay, service incentive leave pay, and holiday pay.
- Petitioners argued that a loss of a major client led to reduced work hours for the respondents, which they claimed caused disruptions in operations.
- An offer of separation benefits was rejected by the respondents.
Ruling of the Labor Arbiter
- The labor arbiter ruled in favor of the respondents, finding petitioners liable for constructive dismissal and ordering back wages and separation pay.
- The arbiter assessed the monetary liabilities, totaling P3,132,335.57, excluding some respondents who were found to have received their benefits.
- No damages were awarded due to lack of basis.
Ruling of the NLRC
- The NLRC dismissed the petitioners' appeal as time-barred, stating the 10-day appeal period began upon the receipt of the arbiter's ruling by a security guard (Naronio) on September 24, 2001.
- The appeal bond was also deemed insufficient and