Case Summary (G.R. No. 222816)
Factual Background
On January 18, 2012, Reyes reported to the main office in Makati to execute his responsibilities rather than going to the Pasig warehouse. He arrived late the following day due to his son's illness. Upon his late arrival, he received a call from Vinson Co Say, his immediate superior, who ordered Reyes not to report to work anymore. Subsequently, Reyes did not return to work and received a text message from Co Say to meet on January 26, 2012, where he was told to resign, a request he refused, believing his dismissal lacked justification.
Procedural Developments
On February 22, 2012, Reyes filed a complaint for constructive dismissal, later amending it to illegal dismissal. In contrast, Global maintained that Reyes voluntarily stopped reporting to work after accumulating multiple violations of company policies, including unexcused absences and neglect of duties.
Labor Arbiter's Decision
The Labor Arbiter ruled in favor of Reyes on November 28, 2012, finding that he had not intended to quit and that the accusations against him did not support the claim of abandonment of employment. The Labor Arbiter awarded Reyes back wages, separation pay, and attorney's fees amounting to P265,045.
National Labor Relations Commission (NLRC) Ruling
The NLRC affirmed the Labor Arbiter's decision, asserting that Reyes provided sufficient details regarding his dismissal, and that Global had not adequately disproven Reyes' claims. The NLRC highlighted the company's failure to provide evidence of a legal dismissal process, thereby obligating it to demonstrate the legality of the termination.
Court of Appeals (CA) Proceedings
Global appealed to the CA, leading to the overturning of the NLRC's decision on August 27, 2015. The CA found that Reyes failed to furnish clear evidence of his dismissal, contending that mere verbal assertions were not sufficient to constitute dismissal. It ruled that there were no overt acts affirming Reyes's termination.
Petition for Review on Certiorari
Reyes filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the CA's reversal ruling. The key issues raised included whether Reyes was illegally dismissed and whether the CA exhibited grave abuse of discretion.
Supreme Court Findings
The Supreme Court concluded that Reyes had indeed proven his dismissal, taking into account the verbal instruction from Co Say, who possessed the authority to terminate Reyes. The Court underscored that verbal notice, particularly from Reyes's immediate supervisor, could be construed as a valid dis
...continue readingCase Syllabus (G.R. No. 222816)
Case Overview
- Petitioner: Allan John Uy Reyes
- Respondent: Global Beer Below Zero, Inc.
- Case Number: G.R. No. 222816
- Date of Decision: October 04, 2017
- Nature of the Petition: Petition for Review on Certiorari under Rule 45 of the Rules of Court
- Initial Decision: Court of Appeals decision dated August 27, 2015 reversing National Labor Relations Commission (NLRC) ruling
Background Facts
- Allan John Uy Reyes was employed as Operations Manager at Global Beer Below Zero from January 2009 to January 2012.
- On January 18, 2012, Reyes reported to the main office to request a budget for a scheduled delivery.
- On January 19, 2012, Reyes was late for work due to his sick child. He communicated with his superior, Vinson Co Say, who instructed him not to report for work anymore.
- Following this incident, Reyes did not return to work and later received text messages from Co Say requesting a meeting.
- In a meeting held on January 26, 2012, Co Say insisted that Reyes should resign, which Reyes refused, leading him to file a complaint for illegal dismissal.
Claims and Counterclaims
Petitioner’s Claims:
- Reyes claimed constructive dismissal due to Co Say’s verbal instruction not to report to work and subsequent insistence on resignation.
- He asserted that he did not intend to quit as he had filed leave applications and communicated about his work obligations.
Respondent’s Defense:
- Global Beer Below Zero argued Reyes voluntarily stopped reporting for work, citing multiple policy violations including frequent absences without proper notice.
- The company claimed that Reyes had not been dismissed and that his actions indicated abandonment of employment.
Labor Arbiter's Decision
- On November 28, 2012,