Evangelista v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Private respondent Arturo Mendoza, employed as a bus driver by petitioner Augusto Evangelista, filed a complaint for illegal dismissal in April 1977. Mendoza alleged that he was dismissed after seeking assistance from his employer for his child's hospitalization and subsequently for a salary loan from the SSS, which involved submitting forms for the petitioner's accomplishment. Petitioner, conversely, claimed Mendoza was never dismissed and had abandoned his job after the bus he was driving was involved in a traffic accident on April 27, 1977, leading to a charge of reckless imprudence resulting in damage to property. 2. Procedural History: The labor arbiter initially ruled in favor of Mendoza, finding him illegally dismissed and ordering reinstatement with one year's backwages. The National Labor Relations Commission (NLRC) affirmed this decision but increased the backwages to three years. Petitioner's subsequent petition for certiorari (G.R. No. 56388) was granted by the Supreme Court on March 27, 1985, which set aside the NLRC's decision and remanded the case to the labor arbiter for a full hearing, including the outcome of the criminal case. After a new hearing, the labor arbiter again found Mendoza to have been illegally dismissed, ordering reinstatement with one year's backwages and an additional sum. Both parties appealed to the NLRC, which on May 23, 1990, affirmed the labor arbiter's decision, again modifying it to award three years of backwages. 3. The Petition: Petitioner filed the instant petition for certiorari with the Supreme Court, arguing that the public respondent NLRC committed a grave abuse of discretion by upholding the finding of illegal dismissal based on mere conjectures and surmises without substantial evidence. The Court noted that the issue was factual and that it generally relies on the findings of administrative bodies. It further observed that the NLRC's findings were based on positive evidence, not speculation, and that the criminal case related to the traffic accident had been provisionally dismissed. The Court concluded that Mendoza had been illegally dismissed and that the NLRC's decision was well-taken.
Issue(s)
Whether the respondent NLRC committed a grave abuse of discretion in upholding the finding of illegal dismissal. Whether the dismissal was due to the traffic accident or abandonment.
Ruling
The petition is DISMISSED, with costs against petitioner. The questioned decision of the respondent NLRC is well-taken.
Ratio Decidendi
On the issue of grave abuse of discretion and illegal dismissal: The Supreme Court reiterated its stance that it is not a trier of facts and must rely on the findings of administrative bodies like the National Labor Relations Commission (NLRC), absent a showing of grave abuse of discretion. The Court found that the NLRC's findings were not based on surmises or conjectures but on positive evidence presented by the private respondent. This evidence indicated that the dismissal stemmed from the employee's act of seeking assistance from his employer for his child's hospitalization and his subsequent need to secure a salary loan, which involved the employer's signature on SSS forms. The employer's reaction, including scolding and preventing the employee from driving, constituted the basis for the illegal dismissal finding. The Court emphasized that the dismissal was not a consequence of the traffic accident that occurred on April 27, 1977, as the criminal case arising from it was provisionally dismissed. On the issue of the traffic accident and abandonment: The Court clarified that the dismissal was not precipitated by the traffic accident wherein the respondent caused damage to property. It was noted that the criminal case for reckless imprudence resulting in damage to property was provisionally dismissed on March 9, 1988, because the complaining witness could not be located. Therefore, it could not be imputed that the private respondent was negligent in driving the petitioner's bus. Furthermore, the petitioner's allegation that the private respondent abandoned his job because he was in hiding due to an arrest warrant in the criminal case was refuted. The Court reasoned that the private respondent's continued pursuit of his complaint before the labor arbiter, even under those circumstances, demonstrated a clear intention not to abandon his work. The Court also highlighted the unfortunate repeated loss of the case records, attributing the case's prolonged pendency of almost fourteen years to the diligence of the private respondent in pursuing his lawful claim.
Main Doctrine
The Supreme Court is not a trier of facts and must rely on the findings of administrative bodies like the NLRC, unless there is a showing of grave abuse of discretion. The Court affirmed the NLRC's finding of illegal dismissal based on evidence that the dismissal was a consequence of the employee seeking assistance for his child's hospitalization, not due to the traffic accident or abandonment.