Mamerto v. Inciong
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for illegal dismissal against Lucky Garments Manufacturing Company, alleging that their termination was due to union activities amounting to unfair labor practice. They also questioned the orders of the Director of the National Capital Region, Ministry of Labor, and the Deputy Minister of Labor, which dismissed their complaint and granted the company's application for clearance to terminate their services, claiming grave abuse of discretion. Procedural History: Respondent Director Francisco L. Estrella dismissed the complaint and granted the clearance to dismiss. The order noted that out of 28 complainants, 16 were regular employees, 8 were apprentices, and 4 were domestic helpers. Twelve regular employees were dismissed for participating in an illegal sit-down strike from March 7 to March 13, 1979, and refused to accept the memo explaining their absence. Gorgonio Javier was dismissed for repeated violations of company rules and refusal to explain. J. Dacanay, C. Cuaresma, and P. Basallo were dismissed for Absent Without Official Leave (AWOL) after leaving the company compound. Eight apprentices were dismissed for failing to meet training standards. Four individuals were identified as household workers, not employees of the company. On appeal, respondent Deputy Minister Amado G. Inciong affirmed Director Estrella's order. The Deputy Minister clarified the employment status of the complainants, noting that some were apprentices, some were household helpers, and the rest were regular employees. He found that the production decline and paralysis were due to a concerted activity amounting to economic sabotage and an illegal strike, in which the complainants were active participants. He also noted that the Ramo incident was used as an excuse and lacked credible record. Furthermore, the Deputy Minister found that the complainants defaulted in submitting their position papers and evidence, despite being required to do so. The Petition: Petitioners sought to annul and set aside the orders of the public respondents, asserting denial of due process and error in denying their motion for certification for compulsory arbitration. They claimed they were not required to submit position papers and that the minutes of the conciliation hearing were fabricated.
Issue(s)
Whether the public respondents committed grave abuse of discretion in dismissing the petitioners' complaint for illegal dismissal and granting the company's application for clearance to terminate their services. Whether the petitioners were denied due process. Whether the public respondents erred in denying the motion for certification of the issues for compulsory arbitration. Whether the classification of the complainants' employment status (regular employees, apprentices, domestic helpers) was erroneous.
Ruling
The petition is dismissed. The orders of the public respondents are affirmed. The respondent company is ordered to pay all complainants who are regular employees financial assistance equivalent to one-half month for every year of service.
Ratio Decidendi
On the alleged grave abuse of discretion and illegal dismissal: The Court found no grave abuse of discretion on the part of the public respondents. The dismissals were for just causes, including participation in an illegal sit-down strike, violation of company rules, and AWOL. The record supported the finding that the production decline was due to a concerted activity amounting to economic sabotage and an illegal strike, in which the petitioners were active participants. The petitioners failed to show that their dismissal was wrongful, thus defeating their allegation of illegal dismissal. The Court reiterated that the findings of fact of public respondents are conclusive and binding if supported by substantial evidence. On the denial of due process: The Court held that the petitioners were not denied due process. They were required to submit their position paper and evidence during the conciliation stage but failed to do so, instead filing a motion for compulsory arbitration which was denied. The Court found that the petitioners had sufficient opportunity to be heard and present their evidence, but they opted not to, thus they could not avoid the effects of their omission. The claim that they were not required to submit position papers was found to be self-serving and not supported by evidence, and could not prevail over the presumption of regularity. On the denial of compulsory arbitration: The Court agreed with the Solicitor General that the nature of the case did not require submission to compulsory arbitration as no intricate question of fact or law was involved. The primary issue was termination, which was a factual matter within the competence of the labor officials. On the classification of employment status: The Court found no merit in the petitioners' claim that the classification of employees as apprentices and domestic helpers was erroneous. This was a finding of fact supported by documentary evidence and positive testimonies, and thus could not be disturbed. The questioned orders correctly cited the documentary evidence on record to support these factual findings.
Main Doctrine
The Supreme Court affirmed the dismissal of petitioners' complaint for illegal dismissal and the grant of clearance to terminate their services, finding that the public respondents did not commit grave abuse of discretion as the dismissals were for just causes and petitioners were afforded due process. The Court also upheld the classification of employees and the denial of the motion for compulsory arbitration.