Madrigalejos v. Galotera
REITERATIONFacts
The Antecedents: Reynaldo Madrigalejos (petitioner) was employed as a truck driver by Geminilou Trucking Service (respondents) to haul and deliver products. The petitioner alleged that he was constructively dismissed after refusing to sign a contract entitled "Kasunduan Sa Pag-Upa ng Serbisyo," which he believed would alter his employment status to contractual and included a waiver of accrued benefits. He further claimed his services were terminated effective November 28, 2004, following his refusal. Procedural History: The petitioner filed a complaint for constructive dismissal and various monetary claims with the National Labor Relations Commission (NLRC). The Labor Arbiter ruled in favor of the petitioner, finding illegal dismissal and ordering reinstatement with backwages. However, the NLRC reversed this decision on appeal, finding no termination of employment and directing the petitioner to report back to work. The NLRC's denial of the petitioner's motion for reconsideration led to an appeal to the Court of Appeals (CA). The CA, by Resolution of April 25, 2007, denied the petitioner's appeal, affirming the NLRC's findings. The CA also denied the petitioner's subsequent motion for reconsideration. The Petition: The petitioner seeks review of the Court of Appeals' decision via a Petition for Review on Certiorari, arguing that the appellate court misappreciated the evidence in ruling that he was not constructively dismissed and that the employer bears the burden of proof to demonstrate an unjustified refusal to report for work. The petitioner contends that his refusal to sign the "Kasunduan" and the subsequent termination of his services constitute constructive dismissal. The respondents, in their comment, maintain that the factual findings of the appellate court are conclusive as they are supported by substantial evidence.
Issue(s)
Whether the petitioner was constructively dismissed. Whether the employer bears the burden of proof to show unjustified refusal to report for work.
Ruling
The petition is denied. The Court affirmed the findings of the NLRC and the Court of Appeals that the petitioner was not constructively dismissed.
Ratio Decidendi
On the issue of constructive dismissal: The Court held that the petitioner's claim of constructive dismissal was unsubstantiated by the required quantum of proof, which is substantial evidence. The lone piece of evidence presented by the petitioner was an unsigned copy of the "Kasunduan Sa Pag-Upa ng Serbisyo." This fell short of the standard of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. The Court found that the appellate court did not err in sustaining the respondents' claim that the petitioner was not dismissed. Instead, the records showed that the petitioner simply failed to report for work after an altercation with a fellow driver, an incident that was subjected to conciliation proceedings before the Sangguniang Barangay. The employer's evidence, including the Sangguniang Barangay records, supported their assertion that the petitioner unilaterally decided to stop reporting for work. Therefore, the petitioner's bare allegations of constructive dismissal must fail for lack of substantial evidence. On the burden of proof: While the petitioner argued that the employer bears the burden of proof to show unjustified refusal to report for work, the Court found that the employer presented substantial evidence supporting their claim. The NLRC, in reversing the Labor Arbiter, gave probative weight to the respondents' evidence, which included pertinent Sangguniang Barangay records. These records corroborated the respondents' assertion that the petitioner stopped reporting for work following an incident with a fellow driver. Thus, the employer successfully discharged its burden by presenting evidence that the petitioner's absence was voluntary and not a result of constructive dismissal.
Main Doctrine
A bare allegation of constructive dismissal, unsubstantiated by substantial evidence, must fail, especially when the employer presents evidence showing the employee unilaterally stopped reporting for work after an altercation.