Title
Polymedic General Hospital vs. National Labor Relations Commission
Case
G.R. No. 64190
Decision Date
Jan 31, 1985
Janitor Pasadilla claimed illegal dismissal after alleged forced resignation; employer failed to prove just cause, leading to reinstatement with reduced back wages.

Case Summary (G.R. No. 64190)

Employment Background and Termination Process

Ricardo Pasadilla was employed by Polymedic General Hospital as a janitor starting in August 1979, receiving a monthly salary of P380.00, plus an allowance. On August 6, 1981, the hospital initiated a clearance application to terminate his employment, citing two instances of being caught sleeping on duty and one instance of abandonment of post. Consequently, Pasadilla was placed under preventive suspension. He opposed this clearance application and subsequently filed a complaint for illegal dismissal, leading to a joint hearing of both cases.

Hearing Proceedings and Evidence Submission

During the initial hearing held on December 11, 1981, Pasadilla presented a position paper along with supporting affidavits and documentary evidence. However, the petitioner failed to present any evidence or personnel at the subsequent hearing on December 18, 1981. Thus, the Labor Arbiter permitted Pasadilla to present his case ex parte. The testimony provided by Pasadilla included details of his employment and the allegations against him, which he vehemently denied, claiming he had not been previously reprimanded or suspended for any alleged violations.

Labor Arbiter's Decision

On January 19, 1982, the Labor Arbiter issued a decision favoring Ricardo Pasadilla, ordering his reinstatement along with back wages and the retention of his seniority rights. The petitioner subsequently appealed this decision, challenging the sufficiency of evidence that supported Pasadilla's claims of illegal dismissal.

Commission's Affirmation of Labor Arbiter's Decision

The National Labor Relations Commission (NLRC) dismissed the appeal filed by Polymedic General Hospital, affirming the Labor Arbiter's decision. The Commission found that the petitioner had not presented sufficient evidence to counter Pasadilla's claims or justify his dismissal.

Supreme Court Analysis of Petitioner’s Claims

The Supreme Court analyzed the petitioner's assertion that the evidence presented was insufficient and deemed the testimony of Pasadilla self-serving. Nevertheless, it highlighted the absence of supporting evidence from the petitioner to validate its claims against Pasadilla. The Court underscored that the burden of proof rested on the employer to demonstrate a lawful basis for dismissal, particularly abse

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