Union Motor Corp. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Alejandro A. Etis, an automotive mechanic awarded multiple times for his performance, was employed by Union Motor Corporation. On September 22, 1997, Etis informed the company nurse he needed to take a sick leave due to a severe toothache. He continued to be absent as advised by his doctor and dentist, who scheduled a tooth extraction for September 27, 1997, and later rescheduled it to October 4, 1997, due to persistent inflammation. Despite these circumstances, Union Motor Corporation issued a memorandum on October 2, 1997, terminating Etis's employment for allegedly incurring more than five consecutive absences without proper notification, deeming it abandonment of office. Procedural History: Upon his recovery and attempted return to work, Etis was denied re-entry and informed of his termination. He sought assistance from his union, which pursued a grievance before the National Conciliation and Mediation Board (NCMB), but his complaint was dismissed. Subsequently, Etis filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC). The Labor Arbiter initially dismissed Etis's complaint, ruling that his ten-day absence was unsubstantiated and constituted gross neglect of duty. However, the NLRC reversed this decision, finding Etis's absences justifiable due to his documented illness and ordering his reinstatement with backwages. Union Motor Corporation's motion for reconsideration was denied. The company then filed a petition for certiorari with the Court of Appeals (CA), which affirmed the NLRC's ruling. The CA also denied the company's motion for reconsideration. The Petition: Union Motor Corporation filed this petition for review on certiorari under Rule 45 of the Rules of Court, challenging the Court of Appeals' decision. The petitioner argues that the CA erred in giving significant evidentiary weight to the medical certificates submitted by Etis, contending they were not notarized and thus lacked probative value. Furthermore, the petitioner asserts that the CA committed a reversible error in ruling that Etis was illegally dismissed, maintaining that his absences constituted gross and habitual neglect of duty and abandonment of employment under company rules and the Labor Code. The core of the petition questions the sufficiency and admissibility of Etis's medical evidence and the interpretation of his absences as justifiable rather than grounds for termination.
Issue(s)
Whether the Court of Appeals committed reversible error in giving much evidentiary weight to the medical certificates submitted by the private respondent. Whether the Labor Arbiter committed a reversible error in ruling that the private respondent was illegally dismissed.
Ruling
The petition is denied due course. The Decision of the Court of Appeals in CA-G.R. SP No. 73602 is affirmed.
Ratio Decidendi
On the evidentiary weight of medical certificates: The Court affirmed the rulings of the NLRC and the CA that medical certificates need not be notarized to be admissible and accorded probative weight. The Court emphasized that jurisprudence does not require notarization for medical certificates to be valid evidence. The certificates in question bore the names, licenses, and signatures of the attending physician and dentist, which were not impugned by the petitioner. The Court reasoned that an ordinary worker should not be burdened with having medical certificates notarized for presentation to their employer. The certificates, along with the testimony of the company nurse and the confirmation by the company guard, sufficiently substantiated Etis's illness and the necessity of his absence for treatment and recovery. The Court rejected the petitioner's argument that the absence of a letterhead on one certificate rendered it invalid, noting that the physician's license number was present and the genuineness of the certificates was not effectively rebutted. On the issue of illegal dismissal: The Court upheld the findings of the NLRC and the CA that Etis was illegally dismissed. The Court found that Etis had complied with the requirement of notifying the petitioner of his illness and the reason for his absence. This notification was made verbally to the company nurse, and the petitioner's dispatch of a security guard to Etis's residence confirmed the latter's condition. The Court reiterated that the company rules did not mandate written notice to a specific office. Therefore, Etis's ten-day absence, being medically justified and known to the employer, could not be considered unauthorized or an abandonment of work. The Court also noted that the petitioner failed to prove gross and habitual neglect of duty, especially in light of Etis's unblemished service record and numerous awards, which demonstrated his dedication to his job. The Court concluded that dismissal, being the ultimate penalty, must be based on just cause and supported by clear and convincing evidence, which was lacking in this case.
Main Doctrine
An employee's absence due to a medically certified illness, even if unnotarized, constitutes justifiable absence and does not amount to gross and habitual neglect of duty or abandonment of work, especially when the employer has knowledge of the illness and the employee's service record is unblemished.