Case Summary (G.R. No. 162802)
Factual Background
Leonardo D. Suario, who had been employed by the Bank of the Philippine Islands since March 1969, filed a complaint against the bank for separation pay, damages, and attorney's fees in August 1977. Suario, who had progressed to the position of Credit Investigator-Appraiser-Credit Analyst, requested a six-month leave of absence to attend a pre-bar review in Manila. Initially, his request appeared to be supported by the then Branch Manager but was ultimately limited to a 30-day approval. Following a series of communications with bank officials, Suario proceeded with his review in Manila without a final formal approval for an extended leave, leading to a series of misunderstandings regarding his employment status.
Case Evolution
After Suario's absence, the bank demanded his return to work alleging he had effectively resigned due to failure to report back. Following unsuccessful attempts at conciliation, the case was referred to a Labor Arbiter, who ruled in December 1977, awarding Suario separation pay but dismissing his claims for moral, actual, and exemplary damages as lacking merit. This decision was upheld by the NLRC in October 1978, leading Suario to file a petition for review with the Supreme Court.
Legal Issues Presented
The petitioner claimed mistakes by the NLRC included the denial of damage claims despite findings of illegal dismissal and the rejection of his motion for reconsideration based on specific presidential decrees. The critical issue was whether the NLRC exerted grave abuse of discretion in denying claims for damages beyond the separation pay awarded.
Relevant Jurisprudence and Legal Framework
The Supreme Court examined Article 217 of the Labor Code, which prescribes the jurisdiction of Labor Arbiters and the NLRC over employer-employee disputes and claims for monetary provisions such as separation pay. Amendments made by various presidential decrees were also considered, particularly PD No. 1367, which initially restricted claims for moral damages but was later nullified by PD No. 1691 reinstating the authority of Labor Arbiters to award various damages in labor cases.
Claim for Damages
The Supreme Court ruled against Suario's claim for moral damages, differentiating between the determination of the legality of dismissal, governed by Labor Code standards, and the conditions for awarding moral damages, which are rooted in Civil Code provisions. In the absences of evidence demonstrating bad faith or fraud on the bank
...continue readingCase Syllabus (G.R. No. 162802)
Case Background
- Petitioner: Leonardo D. Suario, representing himself.
- Respondents: Bank of the Philippine Islands, Davao Branch (including the Manager/Cashier) and the National Labor Relations Commission (NLRC).
- Date of Decision: August 25, 1989.
- Case Reference: G.R. No. 50459.
Factual Background
- Employment History: Suario was employed by the bank since March 1969, eventually becoming the head of the loan section by 1976.
- Request for Leave: In March 1976, he requested a six-month leave without pay for a pre-bar review, initially receiving verbal approval from the then Branch Manager, Mr. Armando N. Guilatco.
- Change of Management: Upon the appointment of Mr. Vicente Casino as the new Branch Manager, Suario was informed that the head office only approved a 30-day leave but was advised to proceed with the review based on earlier assurances.
- Communication Issues: After Suario left for Manila on May 17, 1976, he received a letter on August 1, 1976, instructing him to report back for work due to the alleged disapproval of his leave.
- Dismissal Notification: By December 1976, he was verbally informed of his dismissal, with a formal notification stating his termination was effective July 19, 1976.
Legal Proceedings
- Initial Complaint: Suario filed a complaint on August 4, 1977, seeking separati