Kar Asia v. Corona
REITERATIONFacts
1. The Antecedents: Respondents, employees of petitioner KAR ASIA, Inc., a Davao City automotive dealer, filed a complaint for underpayment of wages and attorney's fees. They alleged that they were not paid their Cost of Living Allowance (COLA) as mandated by RTWPB XI Wage Order No. 3 for December 1993 and December 1994. Petitioners countered that the respondents had been paid and that the respondents' picketing caused significant financial losses to the company. 2. Procedural History: The Labor Arbiter initially ruled in favor of the petitioners, ordering the respondents to pay damages and attorney's fees. Upon appeal, the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision but deleted the awards for damages and attorney's fees. The respondents then filed a petition for certiorari with the Court of Appeals, which reversed the NLRC's decision and ordered KAR ASIA, Inc. to pay the respondents the COLA for December 1994 with interest. 3. The Petition: Petitioners KAR ASIA, Inc. and Celestino S. Barretto seek review under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision and resolution. They argue that the appellate court misapprehended facts and based its findings on a supposed absence of evidence contradicted by the record, specifically regarding the payment of the December 1994 COLA. Petitioners also contend that the Court of Appeals exceeded its authority by re-evaluating evidence rather than limiting its review to jurisdictional errors or grave abuse of discretion by the lower tribunals.
Issue(s)
Whether the Court of Appeals erred in finding insufficient evidence of payment for the December 1994 COLA. Whether the Court of Appeals exceeded its jurisdiction in re-evaluating the evidence presented before the Labor Arbiter and NLRC. Whether the claim for December 1993 COLA had prescribed. Whether the respondents were paid their COLA for December 1993 and December 1994.
Ruling
The petition is granted. The decision of the Court of Appeals is reversed and set aside. The decision of the NLRC dismissing the respondents' claims for unpaid COLA for December 1993 and December 1994 is affirmed.
Ratio Decidendi
On the claim for December 1994 COLA: The Court observed that while the respondents initially alleged non-payment, subsequent pleadings indicated they focused their demand on the December 1993 COLA. Even if abandonment was not considered, the Court found a paucity of evidence to substantiate the bare assertions of non-payment. The Court noted that the payrolls for December 1994 showed an allowance of P327.00 for each half of the month, totaling P654.00, the same amount as the December 1993 COLA. Crucially, the Court found that the payslips for December 1994 bore the signatures of the respondents and contained acknowledgments of full compensation, which, by implication, admitted receipt of all components of their pay, including the COLA. The Court held that these signed payslips constitute substantial proof of actual payment, and the Court of Appeals erred in disregarding them in favor of unsigned payrolls. On the Court of Appeals' re-evaluation of evidence: The Supreme Court reiterated that factual findings by quasi-judicial agencies like the NLRC, which have acquired expertise in their specific fields, are generally accorded respect and even finality. The Court found that the Court of Appeals erred in extensively re-evaluating the evidence, going beyond the scope of a writ of certiorari which is limited to determining if the lower tribunals acted without or in excess of jurisdiction or with grave abuse of discretion. On the claim for December 1993 COLA (Prescription): The Supreme Court noted that the action for the payment of the December 1993 COLA had already prescribed, as the complaint was filed on September 24, 1997, which is beyond the three-year prescriptive period under Article 291 of the Labor Code. On the claim for December 1993 COLA (Payment): The Supreme Court found that the payroll for December 1993 clearly showed the signatures of the respondents acknowledging receipt of P654.00. The Court gave no credence to the respondents' claim of harassment, deeming their allegations self-serving and unsubstantiated.
Main Doctrine
Payroll entries, being entries in the course of business, enjoy the presumption of regularity. While the absence of employee signatures in payrolls does not automatically mean non-payment, signed payslips acknowledging full compensation constitute substantial proof of actual payment, including allowances like COLA.