Case Summary (G.R. No. 213814)
Relevant Timeline
Petitioner Quillopa was assigned to various posts, with the last one being the West Burnham Place Condominium in Baguio City. On September 28, 2010, he was informed that he would be placed on a floating status, to which he repeatedly sought follow-up reassurances from the agency. He filed a first complaint on November 11, 2010, for various unpaid financial claims but later settled this claim through a Waiver/Quitclaim and Release on February 3, 2011. However, failing to receive a new assignment, he filed a second complaint on September 14, 2011, claiming illegal dismissal.
Nature of Employment Dispute
The core dispute resides in whether Quillopa's placement on floating status for an extended period constituted an illegal dismissal. Quillopa argued that being on floating status for over 11 months without reassignment amounted to constructive dismissal, claiming that the Waiver/Quitclaim executed after his first complaint did not preclude him from pursuing the second complaint for illegal dismissal.
Labor Arbiter's Decision
The Labor Arbiter ruled in favor of Quillopa, stating that the previous Waiver/Quitclaim only addressed the claims in the first complaint and did not bar him from pursuing the illegal dismissal claim. It was determined that being on floating status beyond six months constituted constructive dismissal, thus awarding Quillopa a total of P205,436.00 for back wages, separation pay, and attorney's fees.
NLRC Findings
The National Labor Relations Commission (NLRC) upheld the Labor Arbiter's decision on May 31, 2012, affirming that the Waiver/Quitclaim did not relate to the illegal dismissal claim. The NLRC found that Quillopa was indeed constructively dismissed given that he was on floating status for longer than legally allowed, which violated labor standards.
Court of Appeals Ruling
The Court of Appeals, however, reversed this decision on February 19, 2014, concluding that the Waiver/Quitclaim represented a severance of the employment relationship and asserting that Quillopa lacked a viable case against QGSIA for illegal dismissal. This dismissal prompted Quillopa to seek further recourse through a petition.
Legal Standards on Constructive Dismissal
The Supreme Court highlighted that the concept of floating status for security guards is a temporary suspension of duty related to the lack of available assignments due to client decisions. This status does not inherently sever the em
...continue readingCase Syllabus (G.R. No. 213814)
Case Background
- The case involves a petition for review on certiorari filed by Rafael B. Quillopa against Quality Guards Services and Investigation Agency (QGSIA) and Ismael Basabica, Jr.
- The petition challenges the Decision dated February 19, 2014, and the Resolution dated July 25, 2014, of the Court of Appeals (CA), which reversed the earlier rulings of the National Labor Relations Commission (NLRC).
- The CA's ruling dismissed Quillopa's complaint for illegal dismissal, claiming that a prior Waiver/Quitclaim and Release severed the employer-employee relationship.
Relevant Facts
- Quillopa was hired as a security guard by QGSIA on March 14, 2003, with assignments that included the West Burnham Place Condominium in Baguio City.
- On September 28, 2010, he was placed on a floating status by the deputy manager, Rhegan Basabica, with assurances of a new assignment.
- Despite follow-ups, Quillopa did not receive a new assignment and remained on floating status.
- On November 11, 2010, he filed a First Complaint for various money claims against respondents but later settled this complaint with a Waiver/Quitclaim and Release on February 3, 2011.
- On September 14, 2011, Quillopa filed a Second Complaint for illegal dismissal, arguing that his prolonged floating status constituted constructive dismissal.
Legal Proceedings
Labor Arbiter's Ruling
- The Labor Arbiter ruled in favor of Quillopa on January 30, 2012, ordering