Title
Philippine Airlines, Inc. vs. National Labor Relations Commission
Case
G.R. No. 102411
Decision Date
Aug 10, 1993
A robbery on a Manila-bound PAL flight implicated security guards and employees. Resigned confessing theft, later challenged as coerced; SC upheld voluntary resignation, dismissing illegal termination claims.
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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

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