Case Summary (G.R. No. 116487)
Charges and Initial Proceedings
In early April 1974, Sajonas and Santos, along with the Supervisors and Managers Association of Marsman, filed unfair labor practice charges against Marsman & Co., Inc. Following this, an invitation was extended to Sajonas to attend a management committee conference, where he was charged with acts including insubordination and gross disrespect towards company officials. Subsequently, an investigation was prompted, resulting in a written report that recommended Sajonas' termination. A similar investigation into Santos on the same day led to a recommendation for his dismissal as well.
Preventive Suspension and NLRC Proceedings
Both petitioners were suspended on May 2, 1974, and Marsman & Co., Inc. subsequently sought clearance for their termination from the NLRC, which was registered as NLRC Case No. LR-3675. Labor Arbiter Ceferina Diosana conducted hearings, ultimately ruling on November 28, 1977, in favor of the petitioners by denying the clearance for their termination and ordering their reinstatement. The unfair labor practice charges against the company were dismissed.
Appeals and NLRC Decision
Marsman & Co., Inc. appealed to the NLRC, which, on September 15, 1978, reversed the labor arbiter's decision, allowing the company to proceed with the dismissals effective from the date of preventive suspension while affirming the dismissal of the unfair labor practice charges. The petitioners subsequently filed a petition for review, citing that the NLRC’s decision lacked evidentiary support and did not conform to applicable law.
Review Process and Legal Standards
The Court clarified that there is no statutory provision allowing appeals from NLRC decisions and that review by a higher court is limited to cases of grave abuse of discretion or when a decision is rendered in excess of jurisdiction. The case law establishes that certiorari under Rule 65 is appropriate only to address jurisdictional issues and not a review of factual conclusions or evidence evaluation.
Findings on Evidence and Misconduct
The Court assessed the allegations against the petitioners, confirming that habitual tardiness and insubordination were demonstrated, undermining their claims against their dismissals. It reiterated that the standards for supervisory positions entail a heightened level of responsibility and adherence to company rules. The failure of petitioners to follow their immediate superior's instructions was considered inexcusable, reinforcing the validity of the employer's loss of trust.
Conclusion on Due Process
The petitioners claimed t
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Case Overview
- Parties Involved: Petitioners Felicito Sajonas and Victor Santos, versus Respondents National Labor Relations Commission (NLRC), Marsman & Co., Inc., and E.G. Vito.
- Case Citation: G.R. No. L-49286
- Date of Decision: March 15, 1990
- Court: Supreme Court of the Philippines
Background of the Case
- Employment History:
- Felicito Sajonas had been employed with Marsman & Co., Inc. for 7 years and 11 months.
- Victor Santos had been with the company for 6 years and 9 months.
- Initial Labor Actions:
- In early April 1974, both petitioners, along with the Supervisors and Managers Association of Marsman, filed charges of unfair labor practice against the company.
Investigative Proceedings
- Charges against Sajonas:
- Insubordination
- Unsatisfactory attendance
- Gross disrespect to company officials
- Fraud and deceit
- Making false and malicious statements about the company
- Charges against Santos:
- Similar charges of insubordination, habitual tardiness, gross disrespect, fraud, and misrepresentation.
Management Response
- Preventive Suspension:
- Petitioners were placed under preventive suspension on May 2, 1974.
- Request for Clearance:
- On May 7, 1974, Marsman & Co., Inc. filed with the NLRC for clearance to terminate the services of the petitioners.
NLRC Proceedings
- Labor Arbiter's Decision:
- Arbiter Ceferina Diosana conducted hearings and rendered a decision on November 28, 1977, in favor of the petitioners, denying the termination request and ordering rei