Case Summary (G.R. No. 117418)
Employment Background
Roberto H. Pepito began his employment with Stellar Industrial Services, Inc. as a janitor on January 27, 1975, and worked at the Maintenance Base Complex of the Philippine Airlines (MBC-PAL) in Pasay City for approximately 16 years. During his employment, Pepito was reported to have committed several infractions, including tardiness and gambling, but was retained out of humanitarian considerations. On January 22, 1991, Stellar terminated Pepito's employment, citing his "Absent Without Official Leave (AWOL)/Virtual Abandonment of Work" from November 2 to December 10, 1990.
Grounds for Dismissal
Pepito contended that he was unable to attend work during his absence due to severe abdominal pain, substantiated by a medical certificate he submitted indicating his inability to work. Despite this, Stellar maintained disbelief in Pepito's explanation, leading Pepito to file a complaint with the National Labor Relations Commission (NLRC) for illegal dismissal, illegal deductions, and underpayment of wages.
Labor Arbiter's Decision
On December 28, 1992, Labor Arbiter Manuel R. Caday ruled that Pepito's absence was justified due to illness, declaring his dismissal illegal and ordering his reinstatement along with back wages and other benefits. The NLRC affirmed the Arbiter's decision on May 31, 1994, prompting Stellar's appeal based on alleged grave abuse of discretion by the NLRC.
Allegations of Grave Abuse of Discretion
Stellar argued that the NLRC acted with grave abuse of discretion by addressing the issue of abandonment, which Stellar did not initially raise. The company further asserted that the medical certificate supporting Pepito's claim of illness failed to meet standards required to justify his absence and dismissed Pepito by citing past infractions as justifiable grounds for his termination.
NLRC's Analysis and Findings
The Court determined that Stellar failed to establish any grave abuse of discretion within the NLRC's judgement. The NLRC's affirmation of the Arbiter's decision was based on the fact that while abandonment could be a valid ground for dismissal, it was not relevant in this case as Stellar itself did not treat Pepito's absence as abandonment but rather as unexcused absence without prior leave.
Compliance with Company Rules
Despite the company policy demanding formal notification for absences, the Court found that Pepito had reasonably complied with this by informing his supervisor of his illness. The evidence showed that he relayed the nature of his illness upon his initial absence. The Court emphasized that to dismiss him without adequate justification constituted a lack of just cause under labor law principles.
Medical Certificate Evaluation
The Court also refuted Stellar's argument against the validity of the medical certificate, which clearly asserted that Pepito had been examined and was unable to work due to his condition. The interpretation of the medical certificate by Stellar's vice president was deemed unreasonable and lacking in justifiable grounds.
Previous Infractions Considered
On the matter of Pepito's prior infractions being a basis for dismissal, the Court highlighted the princ
...continue readingCase Syllabus (G.R. No. 117418)
Case Citation
- G.R. No. 117418
- Date: January 24, 1996
- Jurisdiction: Supreme Court of the Philippines
Background
- Petitioner: Stellar Industrial Services, Inc. (Stellar)
- Respondents: National Labor Relations Commission (NLRC) and Roberto H. Pepito
- Nature of the Case: Special civil action for certiorari alleging grave abuse of discretion by the NLRC.
Employment Context
- Employment Start Date: January 27, 1975
- Position: Janitor assigned to the Maintenance Base Complex of the Philippine Airlines (MBC-PAL).
- Duration of Employment: Approximately 15 years.
- Infraction History: Multiple infractions including tardiness and gambling; however, retained for humanitarian reasons.
Termination of Employment
- Date of Termination: January 22, 1991
- Grounds for Termination: Alleged "Absent Without Official Leave (AWOL)/Virtual Abandonment of Work" due to absences from November 2 to December 10, 1990.
- Respondent’s Defense: Pepito claimed absences were due to severe stomach pain, supported by a medical certificate.
Legal Proceedings
- Initial Complaint: Filed by Pepito against Stellar for illegal dismissal, illegal deductions, and underpayment of wages.
- Labor Arbiter's Decision (December 28, 1992):
- Declared Pepito's dismissal as illegal.
- Ordered reinstatement with back wages and other benefits.
Appeal to the NLRC
- NLRC's Affirmation: The decision of the labor arbiter was affirmed, prompting Stellar