Sandoval Shipyards v. Clave
REITERATIONFacts
1. The Antecedents: Sergio Sinday, employed as a carpenter by Sandoval Shipyards, Inc., applied for an indefinite leave of absence on May 4, 1976. The petitioner's manager offered a fifteen-day leave, which Sinday allegedly refused. Subsequently, Sinday failed to report for work starting May 26, 1976, leading the petitioner to file a clearance application for dismissal for abandonment of work for Sinday and 38 other employees on August 20, 1976. 2. Procedural History: Sergio Sinday filed a complaint for reinstatement and back wages, alleging wrongful dismissal. The Regional Director of the Department of Labor initially ordered reinstatement, which was affirmed by the Acting Secretary of Labor. The petitioner appealed to the Office of the President, where Presidential Executive Assistant Jacobo C. Clave initially stayed the execution of the decision but ultimately rendered a decision on November 27, 1978, dismissing the appeal for lack of merit and lifting the stay order. 3. The Petition: This is an original special civil action for certiorari seeking to set aside the order of Presidential Executive Assistant Jacobo C. Clave, which affirmed the reinstatement order of the Regional Director. The petitioner argues that the finding of a one-month leave grant is not supported by substantial evidence and is contradicted by Sinday's own application for an indefinite leave, which was disapproved. The petitioner contends that Sinday abandoned his work and that the lower tribunals acted with grave abuse of discretion in ordering reinstatement.
Issue(s)
Whether the public respondents acted with grave abuse of discretion amounting to lack of jurisdiction in ordering the reinstatement of private respondent Sergio Sinday. Whether the petitioner was denied due process of law.
Ruling
The petition for certiorari is GRANTED. The decision of the public respondent, Hon. Jacobo C. Clave, and the order of the Regional Director dated March 16, 1977, ordering the reinstatement of Sergio Sinday are set aside and the complaint of Sergio Sinday for reinstatement in TFU Case No. 786 against Sandoval Shipyards, Inc. is DISMISSED.
Ratio Decidendi
On the issue of reinstatement and grave abuse of discretion: The Supreme Court found that the finding that Sergio Sinday was granted a one-month vacation leave was not supported by substantial evidence, relying instead on Sinday's uncorroborated testimony. This finding was contradicted by Sinday's own application for an indefinite leave of absence, which was clearly disapproved. The Court emphasized that a finding of fact not supported by competent evidence should be disregarded, citing Duran vs. Court of Appeals, Tagumpay Minerals & Mining Association vs. Masangkay, Bautista vs. Carullo, and Sotto vs. Teves. The Court noted that Sinday's application for indefinite leave, which was disapproved, and his subsequent failure to report for work constituted abandonment of his employment. The petitioner's filing of a clearance application for dismissal, citing that Sinday and others had quit their jobs, further supported the claim of abandonment. The Court stated that labor concern should not extend to allowing employees to abandon their work at will and then demand reinstatement, especially when there is a showing that the employee left to seek better employment and only sought reinstatement upon failure to find another job. On the issue of due process: The Court found that the petitioner was not denied due process. The private respondent averred that petitioner was represented by lawyers during hearings and submitted position papers, affidavits, and documentary evidence, which petitioner admitted. The Court also noted that the petitioner filed a clearance application for dismissal, indicating an awareness of the termination process. The argument that the Acting Secretary of Labor's order lacked findings of fact and conclusion of law was implicitly addressed by the Supreme Court's own detailed analysis of the evidence and its conclusion that the labor officials' findings were not supported by substantial evidence, thereby rectifying any procedural deficiency in the administrative appeal.
Main Doctrine
The Supreme Court granted the petition for certiorari, setting aside the order of reinstatement and dismissing the complaint, holding that the employee abandoned his work by failing to report and by applying for indefinite leave which was disapproved, and that the findings of the labor officials were not supported by substantial evidence.