Philippine National Oil Company-Energy Development Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Danilo Mercado was employed by petitioner PNOC-Energy Development Corporation (PNOC-EDC) from August 13, 1979, until his dismissal on June 30, 1985. He was accused of serious dishonesty, including appropriating P680.00 from a purchase of nipa shingles and P8.66 from a payment for rubber stamps, and failing to report a P70.00 discount. He was also accused of violating company rules by being absent without leave and going on vacation leave without prior approval. Procedural History: Mercado filed a complaint for illegal dismissal and various monetary claims. Petitioner PNOC-EDC filed a motion to dismiss, arguing that the NLRC lacked jurisdiction because PNOC-EDC is a government-owned and controlled corporation governed by the Civil Service Law. The Labor Arbiter ruled in favor of Mercado, ordering reinstatement and payment of monetary claims, damages, and attorney's fees. The NLRC affirmed this decision. The case was elevated to the Supreme Court via a petition for certiorari. The Petition: Petitioner PNOC-EDC sought to set aside the NLRC Resolution, raising two main issues: (1) whether matters affecting PNOC-EDC are within the jurisdiction of the Labor Arbiter and NLRC, and (2) whether the reinstatement and monetary awards were justified.
Issue(s)
Whether matters of employment affecting PNOC-EDC, a government-owned and controlled corporation, are within the jurisdiction of the Labor Arbiter and the NLRC. Whether the Labor Arbiter and the NLRC were justified in ordering the reinstatement of private respondent, payment of his savings, proportionate 13th month pay, damages, and attorney's fees.
Ruling
The petition is DENIED, and the resolution of respondent NLRC dated July 3, 1987, is AFFIRMED with the modification that the moral damages are reduced to Ten Thousand (P10,000.00) Pesos, and the exemplary damages reduced to Five Thousand (P5,000.00) Pesos.
Ratio Decidendi
On the issue of jurisdiction: The Court reiterated the ruling in PNOC-EDC vs. Leogardo that employees of government-owned or controlled corporations (GOCCs) incorporated under the General Corporation Law are subject to the Labor Code, not the Civil Service Law. The test for coverage under Civil Service Law is the manner of creation of the GOCC; those created by special charter are covered, while those incorporated under the General Corporation Law are not. Since PNOC-EDC was incorporated under the General Corporation Law, its employees fall under the jurisdiction of the NLRC. The Court also noted that even if the 1973 Constitution was in effect during the initial proceedings, the 1987 Constitution governs the decision of the NLRC, which was promulgated in 1987. The jurisdiction of the NLRC was thus affirmed. On the issue of justification for reinstatement and monetary awards: The Court found that the accusations of dishonesty and violations of company rules against private respondent Mercado were not supported by substantial evidence. The supplier of the nipa shingles clarified that the full purchase price was paid, and there was no evidence of an unreported discount. Similarly, the alleged appropriation of P8.66 from the rubber stamp transaction lacked proof. The alleged violations of company rules were also found to be unsubstantiated, with Mercado providing satisfactory explanations. The Court emphasized that while loss of trust is a valid ground for dismissal, it must have a basis, which was absent in this case. Therefore, the reinstatement and monetary awards were deemed justified based on the findings of fact by the Labor Arbiter and NLRC, which are accorded respect due to their expertise. The Court held that due process was satisfied because both parties were given the opportunity to submit their respective position papers and motions for reconsideration. The petitioner's submission of a position paper and a motion for reconsideration demonstrated that it had an opportunity to ventilate its side. The Court cited Odin Security Agency vs. De la Serna for the principle that the fundamental law abhors the absolute lack of opportunity to be heard, not the absence of previous notice. The petitioner's subsequent appeal also served to cure any potential procedural irregularities. The Court reiterated the principle that findings of administrative agencies with expertise, such as the NLRC, are accorded not only respect but even finality. Judicial review is limited to issues of jurisdiction or grave abuse of discretion, and does not extend to evaluating the sufficiency of the evidence. The Court found no substantive reason to depart from these established principles in this case, as the NLRC's findings were supported by the records and were not contradicted by the petitioner. While affirming the general justification for the awards, the Court found it proper to reduce the moral damages from P30,000.00 to P10,000.00 and exemplary damages from P20,000.00 to P5,000.00, likely to align with established jurisprudence on such awards in similar cases.
Main Doctrine
Employees of government-owned or controlled corporations incorporated under the General Corporation Law are subject to the Labor Code, not the Civil Service Law. The NLRC has jurisdiction over labor disputes involving such corporations. Furthermore, due process is satisfied when parties are given the opportunity to submit position papers and motions for reconsideration.