Hda. Dapdap I v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Nine (9) workers of Hda. Dapdap I, including respondent Pedro Barrientos Jr., filed a complaint for illegal dismissal against its owner, Magdalena Fermin. They alleged they had been working since 1977 but were terminated on January 27, 1992, without notice or valid ground, for refusing to return a 6-hectare lot given to them for cultivation under an "Amicable Settlement" dated September 30, 1986. They also charged unfair labor practice for attempts to bust the union that forged the settlement. Procedural History: Eight (8) complainants withdrew their complaint, having settled their misunderstanding with management. Pedro Barrientos Jr. remained as the sole complainant and amended the complaint to implead Lumbia Agricultural and Development Corporation (LADCOR), the actual owner of Hda. Dapdap I, as co-respondent. LADCOR denied the termination, claiming voluntary abandonment by Barrientos Jr. after March 1, 1992, to transfer to an adjacent farm. LADCOR also asserted its separate legal personality from its president, Magdalena Fermin. The Labor Arbiter ruled in favor of Barrientos Jr., holding LADCOR liable for illegal dismissal but absolving it from unfair labor practice. The Labor Arbiter found the claim of voluntary abandonment not credible and ordered LADCOR to pay separation pay, back wages, and attorney's fees, considering reinstatement no longer feasible due to strained relations. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision in toto, rejecting the abandonment defense for lack of notice of dismissal and concurrence of intent to abandon and overt acts. The Petition: LADCOR filed a special civil action for certiorari with the Supreme Court, assailing the NLRC decision. LADCOR reiterated its contention that Barrientos Jr. voluntarily abandoned his work, while Barrientos Jr. maintained he was illegally dismissed.
Issue(s)
Whether the respondent Pedro Barrientos Jr. voluntarily abandoned his work or was illegally dismissed. Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter's decision.
Ruling
The petition is dismissed. The decision of the NLRC affirming the Labor Arbiter's finding of illegal dismissal and ordering LADCOR to pay back wages, separation pay, and attorney's fees is affirmed.
Ratio Decidendi
On the issue of voluntary abandonment versus illegal dismissal: The Supreme Court emphasized that it is not a trier of facts, and issues of credibility are best left to the Labor Arbiter and NLRC. The Court accords great respect and finality to their findings of fact. Judicial review is limited to issues of jurisdiction or grave abuse of discretion. The NLRC did not commit grave abuse of discretion as it correctly applied the consistent ruling that a charge of abandonment is inconsistent with the immediate filing of a complaint for illegal dismissal. It is inconceivable that an employee working since 1977 and cultivating a substantial lot would abandon his work without apparent reason. The Court cited Judric Canning Corporation v. Inciong stating, "To get a job is difficult; to run from it is foolhardy." Furthermore, intent to abandon cannot be presumed from equivocal acts like interim employment, especially when such employment coincides with the filing of the case and appears to be a means of survival during the pendency of the case. Abandonment cannot be lightly inferred or legally presumed. On whether the NLRC committed grave abuse of discretion: The Supreme Court found no grave abuse of discretion on the part of the NLRC. The NLRC correctly applied established labor jurisprudence by rejecting the defense of voluntary abandonment. The NLRC's affirmation of the Labor Arbiter's decision was based on sound legal grounds, including the lack of notice of dismissal and the absence of overt acts indicating an intent to abandon. The NLRC's rejection of LADCOR's claim of voluntary abandonment was consistent with the principle that such a claim is disproven by the immediate filing of an illegal dismissal case. The Court reiterated that findings of fact by labor tribunals, when affirmed by the NLRC, are binding on the Supreme Court, and review is limited to jurisdictional errors or grave abuse of discretion.
Main Doctrine
A charge of abandonment is inconsistent with the immediate filing of a complaint for illegal dismissal. Furthermore, abandonment cannot be lightly inferred or legally presumed from equivocal acts such as interim employment.