Digitel Telecommunications v. Soriano
REITERATIONFacts
The Antecedents: Digitel Telecommunications Philippines, Inc. (Digitel) hired Mariquit Soriano as Director for Market and Communications. She received a high performance rating initially but later had a rift with a subordinate, Macachor, whose termination she sought but was only transferred. Her subsequent performance reviews showed a decline, with comments suggesting she overcome the "P. Macachor situation" and return to her "sunny and cheerful disposition." Mariquit also gave unfavorable evaluations to her managers, Evelyn P. Inductivo and Andrea S. Arnedo, and sought their termination, but management retained them. Mariquit then filed a letter of resignation, effective June 30, 2000. Subsequently, she executed a Deed of Quitclaim and Release, acknowledging receipt of P97,560.02 and stating her resignation was voluntary. About five months later, Mariquit sought financial assistance from Digitel, and about eleven months after her resignation, she filed criminal complaints against Go and Severino for violation of R.A. 7877 (Anti-Sexual Harassment Law) and/or Article 336 of the Revised Penal Code (Acts of Lasciviousness). Approximately one and a half years after her resignation, Mariquit filed a complaint for illegal dismissal, alleging constructive dismissal due to harassment. Procedural History: The Labor Arbiter dismissed Mariquit's complaint, finding that she voluntarily resigned and that her claims of sexual and professional harassment were not sufficiently established by substantial evidence. The NLRC affirmed the Labor Arbiter's decision, finding that Mariquit voluntarily resigned when her requests for the transfer of subordinates were refused. The Court of Appeals reversed the NLRC, finding that Mariquit was illegally dismissed and ordering Digitel to pay back wages, separation pay, moral and exemplary damages, and attorney's fees. The Petition: Petitioners Digitel, Johnson Robert L. Go, and Eric J. Severino filed a Petition for Review, arguing that the Court of Appeals erred in giving due course to Mariquit's petition for certiorari, disturbing the findings of fact of the NLRC, and finding them guilty of illegal dismissal.
Issue(s)
Whether the Court of Appeals erred in giving due course to the petition for certiorari when there was no grave abuse of discretion on the part of the NLRC or Labor Arbiter. Whether the Court of Appeals erred in reversing and disturbing the findings of fact and conclusions of the NLRC, which were supported by substantial evidence. Whether the Court of Appeals erred in finding petitioners guilty of illegal dismissal, considering the alleged lack of evidentiary support for its factual findings and its ruling on issues not raised, and the credibility of evidence presented. Whether the Court of Appeals erred in awarding backwages, separation pay, and damages.
Ruling
The Petition is GRANTED. The challenged Court of Appeals Decision and Resolution are REVERSED and SET ASIDE. The Decision of the National Labor Relations Commission, which affirmed that of the Labor Arbiter, is REINSTATED.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in giving due course to the petition for certiorari and disturbing the findings of the NLRC: The Supreme Court held that factual findings of labor administrative officials, if supported by substantial evidence, are accorded not only great respect but even finality. Judicial review of NLRC decisions via certiorari is confined to issues of lack or excess of jurisdiction and grave abuse of discretion. The Court found that Mariquit failed to discharge the burden of proving grave abuse of discretion on the part of the NLRC. The NLRC did not disregard the evidence proffered by Mariquit to prove sexual harassment; rather, it found substantial evidence that she voluntarily resigned when her requests for the transfer of subordinates were refused. On the issue of whether the Court of Appeals erred in reversing and disturbing the findings of fact and conclusions of the NLRC: The Court found that factual findings of labor administrative officials, if supported by substantial evidence, are accorded not only great respect but even finality. Judicial review of NLRC decisions via certiorari is confined to issues of lack or excess of jurisdiction and grave abuse of discretion. On the issue of whether the Court of Appeals erred in finding petitioners guilty of illegal dismissal, considering the alleged lack of evidentiary support for its factual findings and its ruling on issues not raised, and the credibility of evidence presented: The Court found that Mariquit's claims of sexual harassment were not sufficiently substantiated by credible evidence. The Court noted the delay in filing the criminal complaint and the constructive dismissal complaint, which cast doubt on the merits of her claims. The Court also found that the evidence presented by Mariquit, including affidavits from friends, was largely hearsay and did not pass the test of credibility when weighed against the counter-affidavits of Digitel's employees and officers. The DOJ's resolution dismissing the criminal complaint for acts of lasciviousness against Go further weakened Mariquit's claims. The Court reiterated that the employer-employee relationship does not automatically discredit an employee's testimony. However, it found Mariquit's claims of sexual harassment to be inconsistent with common experience and observation. The Court also noted that Mariquit's resignation letter did not mention any harassment, and she even thanked Severino, which was contrary to human nature if he were indeed her harasser. The Court found that Mariquit failed to prove that she was constructively dismissed. On the issue of whether the Court of Appeals erred in awarding backwages, separation pay, and damages: Since the Court of Appeals erred in finding illegal dismissal, the award of backwages, separation pay, and damages is also erroneous and must be reversed.
Main Doctrine
The Court reiterated that factual findings of labor administrative officials, if supported by substantial evidence, are accorded not only great respect but even finality, unless there is a showing that they arbitrarily disregarded the evidence before them or had misapprehended evidence of such nature as to compel a contrary conclusion if properly appreciated. Judicial review of decisions of the NLRC via petition for certiorari under Rule 65 is confined only to issues of lack or excess of jurisdiction and grave abuse of discretion on the part of the NLRC.