Case Summary (G.R. No. 54244)
Factual Findings of Quasi-Judicial Agencies
- Factual findings of quasi-judicial agencies, such as the National Labor Relations Commission (NLRC), are generally respected and may be accorded finality if supported by substantial evidence.
- These findings are binding unless established exceptions for review are present.
Burden of Proof on the Employer
- The employer, in this case, San Miguel Corporation, had the burden to prove that Ernesto Javate, Jr. was incapable of performing his regular duties without risking his health or that of others.
- The unilateral decision to "compulsorily retire" the employee placed the onus on the employer to substantiate their claims regarding the employee's fitness for work.
Requirement of Clearance for Termination
- The court determined that Javate was not retired under the company's Health, Welfare, and Retirement Plan but was instead dismissed.
- Such dismissal required clearance from the Department of Labor, which was not obtained by the employer.
Estoppel and Acceptance of Benefits
- The argument that Javate was estopped from contesting his retirement due to acceptance of retirement benefits was rejected.
- Acceptance of benefits does not bar an employee from challenging the legality of their dismissal, as established in previous case law.
Background of the Case
- The case revolves around the compulsory retirement of Ernesto Javate, Jr. following an accident and subsequent medical leave.
- Javate was initially deemed fit to return to work but faced complications due to a typhoon affecting his ability to report back.
Application for Leave and Employer's Response
- Javate's applications for vacation leave were disapproved due to procedural violations, leading to his absences being charged to sick leave.
- The employer claimed that these absences resulted in the exhaustion of sick leave benefits, justifying the compulsory retirement.
Legal Proceedings and Findings
- Javate filed a complaint with the Department of Labor, which ruled in his favor, stating that the employer failed to provide a valid basis for his dismissal.
- The Labor Arbiter's decision was upheld by the NLRC and the Department of Labor, affirming that Javate was wrongfully dismissed.
Employer's Arguments and Court's Rejection
- The employer argued that Javate's retirement was ...continue reading