Case Summary (G.R. No. 206942)
Factual Background
Tatel commenced his employment with JLFP Investigation Security Agency, Inc. on March 14, 1998, and was reportedly posted at BaggerWerken in Manila. He alleged that he was overworked with a twelve-hour shift daily for a monthly salary of P12,400. On October 14, 2009, Tatel filed a complaint regarding underpayment of wages and failure to provide mandatory employee benefits. Shortly thereafter, on October 24, 2009, he was placed on "floating status" for not receiving assignments post his last posting. This led to a separate illegal dismissal complaint filed on May 4, 2010.
Respondents' Defense
In their defense, the respondents contended that Tatel was not dismissed but rather removed from his post for various infractions and subsequently reassigned to two different locations. Despite sending him a memorandum on November 26, 2009, directing him to report back to work, they claimed he ignored it and thus abandoned his job. They also pointed out that Tatel had provided inconsistent accounts regarding his employment details, which they alleged undermined his credibility.
Labor Arbiter's Ruling
The Labor Arbiter dismissed Tatel's illegal dismissal complaint on September 20, 2010, citing his inconsistent statements regarding the timeline of his employment and the nature of his alleged dismissal. The Labor Arbiter concluded that these inconsistencies indicated a lack of merit in Tatel's claims regarding his employment termination.
NLRC's Ruling
On February 9, 2011, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, declaring Tatel's dismissal to be illegal. The NLRC found that the respondents failed to substantiate their claims of abandonment and noted that Tatel had been constructively dismissed due to not being assigned work for over six months. Hence, they ordered his reinstatement and monetary compensation.
CA Ruling
Respondents appealed to the Court of Appeals (CA), which on November 14, 2012, reinstated the Labor Arbiter's dismissal of Tatel's claims. The CA found that the NLRC had acted with grave abuse of discretion and highlighted Tatel's inconsistencies as detrimental to his claims, ultimately concluding that these discrepancies suggested he might not be truthful about his dismissal.
Issue Before the Supreme Court
The key issue presented for resolution was whether the CA erred in finding the NLRC had gravely abused its discretion in determining that Tatel was illegally dismissed.
Supreme Court's Ruling
The Supreme Court found that the petition was meritorious, emphasizing that the jurisdiction of the Court is limited to issues of law. The Court highlighted that the findings of the
...continue readingCase Syllabus (G.R. No. 206942)
Case Background
- The petition for review on certiorari concerns the decisions and resolutions rendered by the Court of Appeals (CA) in CA-G.R. SP No. 119997, which reversed previous rulings made by the National Labor Relations Commission (NLRC).
- The CA reinstated the Labor Arbiter's (LA) decision dated September 20, 2010, dismissing Tatel's labor complaint for lack of merit, contrary to the NLRC's determination of illegal dismissal.
Facts of the Case
- Vicente C. Tatel was employed by JLFP Investigation Security Agency, Inc. as a security guard starting March 14, 1998, and was last posted at BaggerWerken.
- Tatel claimed he worked twelve hours daily for a monthly salary of P12,400.00.
- On October 14, 2009, Tatel filed a complaint against JLFP for underpayment of wages and other benefits.
- Following his filing, he was placed on "floating status" on October 24, 2009, and subsequently filed a second complaint for illegal dismissal on May 4, 2010.
- The respondents contended that Tatel was not dismissed, claiming he was reassigned and later abandoned his work after failing to respond to a return-to-work memorandum.
Labor Arbiter's Ruling
- The Labor Arbiter dismissed Tatel's illegal dismissal complaint, citing the inconsistency in Tatel's statements regarding his employment dates and salary.
- The LA found no credible eviden