Case Summary (G.R. No. 142937)
Sequence of Proceedings
Following their dismissal, Angara and La Victoria filed a motion for reconsideration, which was denied. They subsequently appealed to the Civil Service Commission (CSC). On May 27, 1999, the CSC issued Resolution No. 991110, ordering their reinstatement. PAGCOR's attempts to challenge this resolution led them to the Court of Appeals (CA), which dismissed their petition due to late filing. The denial of PAGCOR’s motion for reconsideration prompted the filing of a petition for review on certiorari with the Supreme Court.
Decision by the Supreme Court
On November 15, 2005, the Supreme Court ruled that the CA erred in dismissing PAGCOR’s petition but ultimately found that PAGCOR's arguments were insufficient to reverse the CSC's ruling. The Court noted that the grounds of loss of trust and confidence were inapplicable, as the respondents were not classified as confidential employees, leading to the denial of PAGCOR’s petition.
Motion for Clarification
On June 14, 2006, the respondents sought a Motion for Clarification, which was effectively a partial motion for reconsideration. They claimed that the Supreme Court failed to include in its decision that they should also receive backwages, allowances, and other benefits lost due to their illegal dismissal. They further sought reimbursement of expenses and attorney’s fees amounting to at least P200,000.00 due to the prolonged nature of the case.
Ruling on the Motion
The Supreme Court partially granted the motion, stating that while parties usually cannot seek relief beyond a decision they did not appeal, in this instance, the relaxation of procedural rules was warranted to uphold the principles of labor and justice. The Court reiterated that Article 279 of the Labor Code entitles illegally dismissed employees not only to reinstatement but also to full backwages and related benefits from the time of their dismissal until reinstatement.
Distinction of Remedies
The Court clarified the distinction between reinstatement and the payment of backwages. Reinstatement restores the employee's position, while backwages compensate for lost income due to an unlawful dismissal. The Court affirmed that the failure to raise a specific issue during prior proceedings did not preclude respo
...continue readingCase Syllabus (G.R. No. 142937)
Case Background
- The case involves Marita A. Angara and Beatriz T. La Victoria, who served as Slot Machine Roving Token Attendants (SMRTAs) for the Philippine Amusement and Gaming Corporation (PAGCOR) at a casino in Davao City.
- On June 28, 1997, both respondents were dismissed from their positions due to alleged lack of trust and confidence.
- After their motion for reconsideration of the dismissal was denied, they filed an appeal with the Civil Service Commission (CSC).
- The CSC, in its Resolution No. 991110 dated May 27, 1999, ruled in favor of the respondents, ordering their reinstatement or placement in comparable positions.
Proceedings in Lower Courts
- PAGCOR filed a petition for review with the Court of Appeals (CA), which dismissed the petition due to late filing.
- PAGCOR’s motion for reconsideration of the CA's decision was also denied.
- Subsequently, PAGCOR brought the case to the Supreme Court through a petition for review on certiorari.
Supreme Court's Initial Ruling
- On November 15, 2005, the Supreme Court ruled that the CA erred in dismissing the petition based on procedural grounds, but found that PAGCOR's arguments did not warrant a favorable judgment.
- The Court determined that the dismissal of the respondents could not be justified by loss of trust and confidence, as they were not classified as confiden