Case Summary (G.R. No. 241814)
Employment Background
Site for Eyes, Inc. engaged Dr. Amor F. Daming as an Optometrist at its Ayala Centro Mall location in Cagayan de Oro City. Initially hired on November 20, 2012, she continued her employment until October 15, 2013, followed by a rehiring under a one-year contract on April 8, 2014, with a salary of P28,000. An increase to P33,000 was agreed upon for the contract renewed on April 20, 2015, but this salary adjustment was never implemented despite Dr. Daming's repeated requests.
Labor Dispute Initiation
The dispute escalated on March 22, 2016, when Dr. Daming along with two colleagues filed for assistance before the Department of Labor and Employment due to unpaid salary, overtime pay, and various other claims. On April 20, 2016, during a hearing, petitioner issued a show cause notice following an audit revealing missing inventory, subsequently barring Dr. Daming from the premises, which led her to file a complaint for illegal dismissal.
Petitioner’s Defense
Site for Eyes, Inc. contended that there was no lawful salary increase and that, if granted, the claim was barred by laches. Petitioner characterized Dr. Daming as a fixed-term employee whose contract simply expired, thus asserting that there had not been a dismissal but a natural conclusion of the employment agreement.
Labor Arbiter’s Decision
The Labor Arbiter determined Dr. Daming to be a regular employee due to the nature of her work, which was essential for the operation of the business. The Arbiter concluded that her barring from the workplace constituted constructive dismissal, awarding her back wages, separation pay, and other financial compensations.
NLRC Ruling
The National Labor Relations Commission (NLRC) upheld the Labor Arbiter's ruling. It asserted that the yearly contracts signed by Dr. Daming were deceptive, meant to bypass the law on regularization, reaffirming her status as a regular employee and that her dismissal was without lawful cause.
Court of Appeals Findings
Petitioner further challenged the decision in the Court of Appeals (CA), which affirmed the NLRC’s findings. The CA ruled that Dr. Daming's employment met the criteria for establishing an employer-employee relationship, thereby rejecting petitioner’s claims of proper fixed-term employment.
Issues Presented
Site for Eyes, Inc. raised several issues on appeal including the CA's alleged errors in affirming the previous decisions, arguing no constructive dismissal occurred, and contesting the monetary awards ordered for back wages and separation pay.
Court’s Review Framework
The Supreme Court referred to the nature of the review process applicable under Rule 45, emphasizing its limitations to whether the CA properly identified any grave abuse of discretion by the NLRC. The Court clarified that it would not re-evaluate evidence already assessed by the lower courts, reinforcing the finality of fact-finding by labor tribunals unless a clear error was identified.
Employment Status Determination
The Supreme Court concurred with the findings that Dr. Daming was a regular employee. It referenced Article 280 of the Labor Code concerning employee classifications, clarifying that fixed-term employment requires mutual agreement and cannot circumvent regular employment classification when the work is essential to the employer's business.
Constructive Dismissal Analysis
The Court elaborated on constructive dismissal, affirming that Dr. Daming's barring from the shop amounted to such, as it effectivel
...continue readingCase Syllabus (G.R. No. 241814)
Background of the Case
- The case revolves around a Petition for Review on Certiorari filed by Site for Eyes, Inc. against Dr. Amor F. Daming following decisions from the Court of Appeals affirming the findings of the National Labor Relations Commission (NLRC).
- The petitioner is a domestic corporation in the optical lens industry, while the respondent was employed as an optometrist starting November 20, 2012, until her illegal dismissal on April 20, 2016.
Employment History
- Respondent Dr. Daming's employment began as a regular optometrist until it was renewed on April 8, 2014, for one year at a monthly salary of ₱28,000.00 and again on April 20, 2015, with an increase to ₱33,000.00.
- Despite the renewal, she did not receive the promised salary increase, leading her to seek assistance from the Department of Labor and Employment.
Events Leading to Dismissal
- Dr. Daming, along with two co-employees, filed a request for assistance regarding unpaid wages and benefits on March 22, 2016.
- During the Single Entry Approach (SEnA) hearing, she was issued a show cause notice regarding missing items from the shop, and subsequently barred from entering the premises, resulting in her dismissal.
Petitioner’s Arguments
- Site for Eyes, Inc. contended that Dr. Daming was a fixed-term employee whose contract simply expired, denying any illegal dismissal.
- They also argued that her claims were barred by laches and that there had been no salary increase granted.
Respondent’s Counterarguments
- Dr. Daming claimed that she pursued her salary increase diligently and that the circumstances of her dismissal were indicative of constructive dismissal.
- She provided evidence including text me