Gallera de Guison Hermanos, Inc. v. Cruz
REITERATIONFacts
The Antecedents: Ma. Asuncion C. Cruz, a cashier and stockholder of Gallera de Guison Hermanos, Inc. (Gallera) since 1976, requested a transfer to Liaison Officer. The company's counsel informed her that the Board could not consider the request as it would result in a salary reduction. Cruz subsequently took a sick leave due to alleged ill treatment. While on leave, Gallera appointed a relative as cashier. Upon Cruz's return, she was informed she would be placed on a 'no work, no pay' basis pending reassignment. She was later designated liaison officer, but her salary was withheld, and her designation removed. Gallera then offered her to return on a 'no work, no pay' basis, excluding allowances. Procedural History: On March 8, 2000, Cruz filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, ordering Gallera to pay separation pay, backwages, and attorney's fees. Gallera appealed to the National Labor Relations Commission (NLRC) but filed the appeal beyond the reglementary period, leading to its dismissal. The NLRC denied Gallera's motion for reconsideration. Subsequently, Gallera filed a petition for certiorari with the Court of Appeals, which, despite reviewing the merits, affirmed the NLRC's decision and found Cruz to have been constructively dismissed, holding the individual petitioners solidarily liable. The Petition: This petition for review seeks to overturn the Court of Appeals' decision affirming the Labor Arbiter's ruling of illegal dismissal. The petitioners argue that Cruz resigned and was estopped from questioning her transfer due to voluntary acceptance. They also dispute the solidary liability of the individual petitioners. The Supreme Court initially denied the petition for failure to appeal within the reglementary period but later reinstated it upon motion for reconsideration. The Court ultimately denied the petition, finding no reason to disturb the unanimous findings of the lower tribunals that Cruz was illegally dismissed and that the petitioners were solidarily liable.
Issue(s)
Whether the Court of Appeals erred in affirming the NLRC's dismissal of the appeal for being filed out of time; and the procedural aspect of the appeal. Whether Cruz was illegally dismissed or constructively dismissed; and the nature of the transfer. Whether the individual petitioners are solidarily liable with Gallera for Cruz's monetary claims.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, upholding the findings that Ma. Asuncion G. Cruz was illegally dismissed and is entitled to separation pay, backwages, and attorney's fees. The individual petitioners were also held solidarily liable.
Ratio Decidendi
On the issue of appeal timeliness and the substantive findings of illegal dismissal; and the procedural aspect of the appeal: While the petitioners' appeal to the NLRC was initially dismissed for being filed out of time, the Supreme Court, in its resolution dated January 12, 2004, granted their motion for reconsideration, thereby reinstating the petition. However, this reinstatement did not alter the substantive outcome of the case. The Court reiterated the well-established rule that findings of fact of the Court of Appeals, when in absolute agreement with the NLRC and the Labor Arbiter, are accorded finality and are binding upon the Supreme Court, provided they are supported by substantial evidence. In this case, the Labor Arbiter, the NLRC, and the Court of Appeals unanimously found that Cruz was illegally dismissed. The Court found no reason to disturb these findings, emphasizing that the petition raised a fundamental factual issue already exhaustively discussed and passed upon by the lower tribunals. The Court ultimately denied the petition for review on certiorari, finding no reversible error in the Court of Appeals' decision that affirmed the Labor Arbiter's ruling of illegal dismissal. On the issue of constructive dismissal and the nature of the transfer: The Court of Appeals found that Cruz was not merely transferred but was constructively dismissed. This was based on the finding that her request for transfer was met with resistance, followed by alleged ill treatment and harassment, and ultimately a reassignment to a liaison officer position which entailed a demotion and reduction in salary and benefits. The subsequent withholding of her salary and removal from the payroll further supported the conclusion that her employment was effectively terminated without just or valid cause. The Court agreed with the appellate court that Cruz did not resign but was removed from her position. On the issue of solidary liability of individual petitioners: The Court of Appeals declared the individual petitioners, Carlos and Pacita Reyes, solidarily liable with Gallera for Cruz's monetary claims. This was based on their assent to and sustenance of Cruz's illegal transfer from cashier to liaison officer. As officers of the corporation who participated in or approved the actions leading to the constructive dismissal, they could be held personally liable for the damages incurred by the employee. The Supreme Court found no error in this conclusion, as corporate officers can be held liable for corporate acts that are tainted with bad faith or malice, or that result in illegal dismissal.
Main Doctrine
Findings of fact of the Court of Appeals, particularly where it is in absolute agreement with that of the NLRC and the Labor Arbiter, are accorded not only respect but even finality and are deemed binding upon the Supreme Court so long as they are supported by substantial evidence.