Five J Taxi v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners Juan S. Armamento, owner and operator of Five J Taxi, hired private respondents Dominador Sibayan and Jose Salcedo as taxi drivers in 1983. The drivers contributed P10.00 daily as a "deposit." In August 1988, private respondents were terminated, and their accumulated deposits were not returned. Procedural History: Private respondents filed a complaint for illegal dismissal and illegal deduction. The Labor Arbiter ruled in their favor, ordering reinstatement with full backwages and reimbursement of deposits. The Research and Information Unit computed the award. Petitioner Armamento opposed, claiming his written Manifestation on December 13, 1988, offering unconditional reinstatement, should stop the running of backwages. The Labor Arbiter and NLRC, through several resolutions, consistently rejected this claim, finding no hard proof of an unconditional offer and clear intent to reinstate. The NLRC denied the motion for reconsideration and remanded the case for computation. Subsequent computations were made, and petitioners' motions for recomputation were denied. The Petition: Petitioners seek to nullify the NLRC Resolution dated January 18, 1991, which allegedly allowed private respondents to recover backwages even after the alleged unconditional offer to return to work.
Issue(s)
Whether the computation of backwages should stop on December 13, 1988, the date petitioners claim they made an unconditional offer of reinstatement. Whether the findings of fact of labor officials are binding on the Supreme Court.
Ruling
The petition is dismissed for lack of merit. The Supreme Court affirmed the NLRC's resolution, holding that the computation of backwages should not be stopped based solely on a bare manifestation of an unconditional offer of reinstatement without sufficient proof of the employer's clear intent to reinstate and the employee's refusal.
Ratio Decidendi
On the issue of the cut-off period for backwages: The Court found that the NLRC correctly rejected the petitioners' claim that the computation of backwages should stop on December 13, 1988. The NLRC meticulously reviewed the records and found no "hard and solid proof" that the respondents had indeed made an unconditional offer of reinstatement, except for the bare manifestation filed on that date. Furthermore, there was no subsequent attempt by the respondents to follow up on this alleged offer of reinstatement. The Court emphasized that conferences were scheduled where the respondents could have formally established the complainants' refusal to return to work, but they failed to do so. The NLRC concluded that the petitioners had not demonstrated a clear intent to reinstate the complainants, and thus, their allegation that the computation of the award should stop when the manifestation was filed could not prosper. The Court also noted that this issue had already been disposed of in previous resolutions of the NLRC, making it too late to argue. On the binding nature of findings of fact of labor officials: The Court reiterated the well-settled rule that findings of fact of labor officials are generally conclusive and binding upon the Supreme Court when supported by substantial evidence. In this case, the NLRC's findings, which were based on the evidence presented and the lack of proof from the petitioners regarding their offer of reinstatement, were supported by substantial evidence. Therefore, the Supreme Court found no reason to disturb the amount of backwages awarded to the private respondents.
Main Doctrine
The computation of backwages should not automatically stop upon the filing of a bare manifestation of an unconditional offer of reinstatement if there is no hard and solid proof that the employer made a clear intent to reinstate and that the employee refused such offer. The employer must demonstrate a clear intent to reinstate and the employee's refusal.