Nitto Enterprises v. National Labor Relations Commission and Roberto Capili
NEW DOCTRINEFacts
The Antecedents: Petitioner Nitto Enterprises hired Roberto Capili as an apprentice machinist, molder, and core maker for six months. During his apprenticeship, Capili accidentally injured an office secretary while handling glass. Later that day, he operated a power press machine without authority and injured his own thumb. The company covered his medical expenses. The following day, Capili was asked to resign, which he did, signing a resignation letter and a quitclaim and release. Procedural History: Three days after signing the quitclaim, Capili filed a complaint for illegal dismissal. The Labor Arbiter found the termination valid and dismissed the money claims, ordering the company to pay P500.00 as financial assistance. The NLRC reversed this decision, declaring Capili a regular employee and ordering reinstatement with backwages, and further hearing of money claims. The Petition: Petitioner Nitto Enterprises filed a petition for certiorari seeking to annul the NLRC decision, arguing that the NLRC committed grave abuse of discretion in holding that Capili was not an apprentice and that the termination was not adequately proven to have a valid cause.
Issue(s)
Whether the NLRC committed grave abuse of discretion in holding that private respondent was not an apprentice. Whether the NLRC committed grave abuse of discretion in holding that petitioner had not adequately proven the existence of a valid cause in terminating the service of private respondent.
Ruling
The petition is denied. The decision of the National Labor Relations Commission is affirmed.
Ratio Decidendi
On Issue 1: The Court affirmed the NLRC's finding that Roberto Capili was not a mere apprentice. Article 61 of the Labor Code mandates that apprenticeship agreements must conform to rules issued by the Minister of Labor and Employment and be part of an apprenticeship program duly approved by the Minister. While an agreement was executed and a program prepared, the agreement was filed only after its execution and lacked DOLE approval. Prior approval by the DOLE is a sine qua non for the validity of an apprenticeship agreement. Without this, the agreement has no force and effect, rendering Capili a regular employee under Article 280 of the Labor Code, entitled to security of tenure. On Issue 2: The Court upheld the NLRC's finding that the termination was not for a valid cause due to lack of due process. The twin requirements of notice and hearing must be met for a valid dismissal. The employer must furnish the employee with two written notices: one apprising the employee of the grounds for dismissal and another informing them of the decision. The facts indicate that Capili was made to sign a resignation letter and quitclaim shortly after the incidents, suggesting a summary dismissal rather than a procedurally compliant termination. His claim of being "strong-armed" into signing, coupled with the immediate filing of an illegal dismissal case, further supports the conclusion that the resignation was not voluntary and the dismissal was illegal.
Main Doctrine
An apprenticeship agreement is valid only if it conforms to the rules issued by the Minister of Labor and Employment and is part of an apprenticeship program duly approved by the Minister of Labor and Employment. Without such prior approval, the agreement has no force and effect, and the employee should be considered a regular employee.