Flexo Manufacturing Corporation v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Petitioner Flexo Manufacturing Corporation employed private respondent Virgilio M. Mantes as a slitting machine operator from 1966 until March 8, 1974, when he was terminated for abandonment. He was rehired on December 20, 1975. On April 18, 1977, Mantes was unable to report for work due to influenza and sent a handwritten note to management via a coworker. He presented a medical certificate for his absence from April 18 to April 23, 1977, upon attempting to return to work on April 25, 1977, but was refused an excuse slip by the Production and Personnel Managers. Subsequently, Mantes received a notice that his termination was effective May 20, 1977, due to abandonment. 2. Procedural History: Private respondent Mantes filed a complaint for illegal dismissal on May 25, 1977, with the Department of Labor. Labor Arbiter Ricarte T. Soriano ruled in favor of petitioner Flexo Manufacturing Corporation on May 23, 1978, granting its application for clearance to terminate Mantes and dismissing Mantes' complaint. Mantes appealed this decision to the National Labor Relations Commission (NLRC). On October 17, 1980, the NLRC reversed the Labor Arbiter's decision, ordering petitioner to reinstate Mantes with full backwages and denying the clearance to dismiss. This NLRC decision is the subject of the current petition. 3. The Petition: Petitioner Flexo Manufacturing Corporation filed this petition for certiorari, arguing that the NLRC committed grave abuse of discretion. The petition raises three main contentions: (1) the NLRC entertained the private respondent's appeal despite petitioner not being notified, violating due process; (2) the NLRC failed to inquire into the timeliness of the private respondent's appeal; and (3) the NLRC erred in ordering reinstatement with full backwages for an extended period, as the Labor Arbiter's factual findings were not disturbed. The petition seeks to review and reverse the NLRC's decision.
Issue(s)
Whether the NLRC gravely abused its discretion in entertaining the private respondent's appeal despite petitioner's claim of lack of notice, thereby violating due process. Whether the NLRC erred in failing to inquire into the timeliness of the private respondent's appeal. Whether the NLRC gravely abused its discretion in ordering the reinstatement of the private respondent with full backwages.
Ruling
The petition is devoid of merit. The Supreme Court affirmed the decision of the NLRC, modifying only the computation of backwages to three (3) years without qualification or deduction. The restraining order previously issued was lifted.
Ratio Decidendi
On the issue of lack of notice and due process: The Court held that the petitioner's allegation of not being served a copy of the notice of appeal is belied by the evidence, which shows that a copy was mailed to petitioner's counsel of record and received by his office. Even if there was a failure to serve a copy of the appeal, the Court reiterated its ruling in J.D. Magpayo Customs Brokerage vs. NLRC that such failure is not a jurisdictional defect and does not justify the dismissal of the appeal. The Court emphasized that the entire record of the case was open for review by the NLRC, and the absence of an answer to the appeal would not significantly prejudice the petitioner, as no new evidence or arguments were presented. The NLRC relied on the evidence and arguments already presented before the Labor Arbiter, which petitioner had the opportunity to refute. Therefore, petitioner was not denied due process. On the timeliness of the appeal: The Court found that the private respondent's appeal was seasonably filed. The Labor Arbiter's decision was dated May 23, 1978. Private respondent obtained a xerox copy on July 6, 1978. Counting ten working days from July 6, 1978, the deadline for filing the appeal was July 20, 1978, which was the date the notice of appeal was filed. Furthermore, the Court noted that private respondent's counsel received a copy of the decision only on August 21, 1978, meaning the appeal was filed even before the ten-day period for the counsel had started to run. The Court stressed that dismissing an employee's appeal on a purely technical ground is inconsistent with the constitutional mandate to protect labor, and labor laws should be interpreted liberally. On the legality of the dismissal and reinstatement with backwages: The Court found that the private respondent was illegally dismissed. The NLRC's findings, which were adopted by the Supreme Court, indicated that Mantes' absence from April 18 to 23, 1977, was justified by illness, supported by a medical certificate and proper notice given to management through a co-worker and foreman. The refusal to allow Mantes to report for work on April 25, 1977, despite presenting the medical certificate, and the subsequent termination for abandonment were deemed unjustified. The Court reiterated that abandonment requires a deliberate and unjustified refusal to resume employment, accompanied by overt acts, which was not present here. The fact that Mantes immediately filed a complaint for illegal dismissal after receiving the clearance application further negated the claim of abandonment. Consequently, Mantes was entitled to reinstatement with backwages. The Court modified the award of backwages to three (3) years, computed without qualification or deduction, in line with its policy to fix backwages at a just and reasonable level to avoid delays.
Main Doctrine
Failure to furnish a copy of the notice of appeal to the appellee is not a jurisdictional defect that warrants dismissal of the appeal, and the liberal application of labor laws mandates that technicalities should not prevail over substantial justice, especially when the appeal raises issues of illegal dismissal and backwages.