Case Summary (G.R. No. 102411)
Background of the Case
- The case originated from a robbery involving a Japanese national, Akira Saikyo, on a Philippine Airlines (PAL) flight on November 13, 1984.
- The robbery occurred at the Manila International Airport, where Saikyo's attache case was forcibly opened, resulting in the theft of Y500,000.00 and US$400.00.
- A security guard, Vilma Saludario, was approached by another guard, Francis P. Dagui, who left money with her, claiming it was his.
Investigation and Admissions
- Dagui was later seen counting dollar bills, prompting a report to his superiors, leading to an investigation.
- Dagui admitted to possessing foreign currency that was part of his share from the robbery, implicating other PAL employees, including Dominador Zapanta, Cesar Lopez, Edgardo Ferrer, and Wilfredo R. Omar.
- Dagui offered a bribe to his supervisor to remain silent, which led to a plan to entrap him.
Resignation and Acceptance
- The implicated employees, including Dagui, signed a joint resignation letter on November 26, 1984, admitting their involvement in the theft.
- Their resignations were accepted by PAL on January 12, 1985, with forfeiture of benefits and prejudice to future employment, while a criminal case was pursued against Bonifacio Rodriguez, the main perpetrator.
Legal Proceedings Initiated by Employees
- On January 14, 1986, Ferrer, Zapanta, Lopez, and Omar filed a complaint with the NLRC, claiming coercion in signing the resignation letter and lack of due process in their dismissal.
- The complaint was partially dismissed for lack of interest from Lopez and Omar, leaving only Ferrer and Zapanta's claims to proceed.
Labor Arbiter's Decision
- The Labor Arbiter ruled in favor of Ferrer and Zapanta, ordering their reinstatement and back wages, which was affirmed by the NLRC.
- PAL's appeal to the Supreme Court sought to nullify the NLRC's decision, arguing that the resignations were voluntary.
NLRC's Findings
- The NLRC found that PAL failed to prove the voluntariness of the resignations and that the employees were not afforded due process.
- The joint nature of the resignation letter raised suspicions about its authenticity, as individual resignations would have been more typical if voluntary.
Testimonies and Evidence
- Testimonies from PAL security personnel contradicted the claims of coercion, indicating that the employees had pleaded for leniency and voluntarily resigned.
- The Labor Arbiter dismissed these testimonies as inconsistent, despite evidence supporting the employees' admissions of guilt.
Court's Analysis and Conclusion
- The Supreme Court found that the NLRC's ruling disregarded substantial evidence and testimonies that supported PAL's position.
- The C...continue reading