Case Summary (G.R. No. 143511)
Factual Background
Joey B. Teves was employed by PLDT as Clerk II since 1981 until his termination on June 1, 1992. His dismissal stemmed from three unauthorized absences within three years, according to a memorandum issued by PLDT on May 29, 1992. The first absence occurred when Teves was caring for his wife post-childbirth, the second was due to his children’s illnesses, and the third absence involved intentional non-appearance to delay financial obligations. Teves contested the termination by stating justifiable reasons for his absences and subsequently filed a complaint for illegal suspension and dismissal.
Decisions of Lower Courts
The Labor Arbiter initially ruled in favor of PLDT, declaring the termination legal but awarding Teves financial assistance. Upon appeal, the National Labor Relations Commission (NLRC) reversed this decision, ruling Teves's dismissal illegal and ordering reinstatement with full backwages and benefits. The NLRC justified Teves’s prolonged absence due to family emergencies, recognizing these circumstances as meritorious enough to reconsider the disciplinary actions taken against him.
Appellate Review
PLDT pursued a certiorari petition challenging the NLRC’s decision. The Court of Appeals (CA) upheld the NLRC ruling, noting that while PLDT had complied with due process requirements, the severity of the dismissal was disproportionate to the infractions. The CA asserted that the first two absences were justified, and the absence from February 11 to 19, 1992, though unjustified, was not sufficient to warrant dismissal. PLDT's motion for reconsideration was subsequently denied.
Main Arguments by Petitioner
In its appeal, PLDT argued that Teves's previous absences were consistently unauthorized and should validate the dismissal under the totality of infractions doctrine. PLDT emphasized the necessity of adherence to company regulations and claimed that Teves's lack of notice constituted willful disobedience, thereby justifying termination. The petitioner contended that Teves did not defend himself against prior sanctions and was thus equally culpable.
Supreme Court’s Evaluation
The Supreme Court reviewed the case focusing on whether grounds existed for Teves's dismissal. It concluded that while the absence from February 11 to 19 was indeed unjustified, previous absences had adequate justification, with Teves having provided necessary explanations post-event. The Court underscored the importance of proportionality between an employee's offenses and the penalties enacted by the employer, emphasizing that dismissal should not be the default consequence of infractions.
Final Judgment and Modifications
The Supreme Court aff
...continue readingCase Syllabus (G.R. No. 143511)
Background and Procedural History
- The case involves a review on certiorari regarding the Decision dated April 24, 2000, and the Resolution dated May 31, 2000, of the Court of Appeals (CA) in CA-G.R. SP No. 50852.
- The CA affirmed the National Labor Relations Commission's (NLRC) Decision that ordered the reinstatement of Joey B. Teves to his former position without loss of seniority rights and with full backwages until reinstated.
- Joey B. Teves was employed by the Philippine Long Distance Telephone Company (PLDT) as Clerk II from 1981 until his termination on June 1, 1992.
Grounds for Termination
- Teves was terminated due to three unauthorized leaves of absence within a three-year period as per an Inter-Office Memorandum dated May 29, 1992.
- The first absence was from August 23 to September 3, 1990, due to complications following his wife's childbirth, which required his assistance at home.
- The second absence occurred from May 29 to June 12, 1991, attributed to the illness of his daughters, for which he communicated his situation through a co-worker.
- The third instance of absence was from February 11 to February 19, 1992, wherein Teves claimed he was trying to manage financial obligations by prolonging payments, a justification deemed unacceptable by PLDT.
Initial Labor Arbiter's Decision
- Labor Arbiter Benigno C. Villarente, Jr. ruled on May 13, 1994, that