Nippon Express Philippines Corp. v. Daguiso
REITERATIONFacts
The Antecedents: Marie Jean Daguiso was employed by Nippon Express Philippines Corporation (NEPC) as a Corporate Human Resource Specialist, later promoted to Corporate Human Resource Supervisor. On June 1, 2012, a dispute arose when Daguiso questioned an email sent by her subordinate, Diane Aguirre, regarding the reassignment of duties concerning attendance monitoring. This led to a shouting match between Daguiso and Aguirre. Later that day, NEPC issued Daguiso a termination letter, citing infractions of company policy on conduct and discipline, including discourtesy, use of indecent language, coercion, intimidation, assault, and refusal to carry out official instructions. NEPC alleged that Daguiso was a constant source of discord and disruption, and that her dismissal was for serious misconduct and willful disobedience. Procedural History: Daguiso filed a complaint for illegal dismissal against NEPC and its officers. The Labor Arbiter ruled that Daguiso was illegally dismissed, ordering NEPC to pay backwages, separation pay, and nominal damages. NEPC did not appeal this decision. Daguiso appealed to the National Labor Relations Commission (NLRC), seeking reinstatement, solidarity liability of a senior manager, and moral and exemplary damages. The NLRC affirmed the Labor Arbiter's decision but modified it by awarding separation pay in lieu of reinstatement, citing strained relations between the parties. Daguiso's motion for reconsideration was denied. Subsequently, Daguiso appealed to the Court of Appeals, which nullified the NLRC's resolutions, ordered Daguiso's immediate reinstatement, and payment of full backwages and benefits. NEPC's motion for reconsideration was denied, leading to the present petition. The Petition: NEPC filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision. NEPC argues that the Court of Appeals erred in disregarding the factual findings of administrative agencies like the NLRC, in ordering reinstatement despite the existence of strained relations, and in granting reinstatement when Daguiso had previously sought execution of separation pay. NEPC contends that the Court of Appeals should have respected the NLRC's finding of strained relations, which justified separation pay instead of reinstatement, and that Daguiso's actions were inconsistent with a claim for reinstatement. NEPC seeks to have the NLRC's resolution reinstated in its entirety.
Issue(s)
Whether the Court of Appeals erred in ordering the reinstatement of respondent Daguiso despite the NLRC's finding of strained relations. Whether the Court of Appeals erred in disregarding the NLRC's findings of fact. Whether Daguiso's motion for partial writ of execution for separation pay is inconsistent with her prayer for reinstatement.
Ruling
The petition is denied. The Decision of the Court of Appeals dated January 5, 2015, and its Resolution dated April 20, 2015, are affirmed. Respondent Marie Jean Daguiso is ordered to be immediately reinstated to her previous position without loss of seniority rights and paid her full backwages, inclusive of allowances, and other benefits computed from the time her compensation was withheld from her up to the time of her actual reinstatement.
Ratio Decidendi
On the issue of reinstatement and strained relations: The Court affirmed the Court of Appeals' ruling that Daguiso should be reinstated. The Court reiterated that reinstatement is the rule for illegally dismissed employees, and the exception of strained relations should not be applied indiscriminately. The NLRC's bases for finding strained relations—Daguiso's insistence on De Vera's personal liability and the shouting match with Aguirre—were deemed insufficient. The Court emphasized that the altercation originated from De Vera bypassing Daguiso, creating a legitimate grievance for Daguiso, and that NEPC should not profit from its own misdeeds. The Court also noted that the filing of a complaint and litigation, while potentially causing hostility, do not automatically preclude reinstatement. The doctrine of strained relations requires clear and convincing proof that the relationship has deteriorated to a point that it would adversely affect the employee's efficiency and productivity, which was not sufficiently established by NEPC. On the Court of Appeals' review of NLRC findings: The Court clarified that while factual findings of administrative agencies like the NLRC are generally accorded respect, it will review the records when the findings of the NLRC and the Court of Appeals are in conflict, as in this case. The Court found that the CA correctly identified the conflict and reviewed the records to determine which finding should be upheld. The CA's reversal of the NLRC's decision on reinstatement was found to be based on a proper evaluation of the evidence and applicable law, particularly concerning the application of the doctrine of strained relations and the principle of security of tenure. On the inconsistency of Daguiso's motion for partial writ of execution: The Court found no merit in NEPC's contention that Daguiso's motion for partial writ of execution for separation pay was inconsistent with her prayer for reinstatement. The Court noted that the motion was filed without prejudice to her appeal before the NLRC. Furthermore, NEPC itself had manifested willingness to pay the monetary award to amicably settle the issue, but Daguiso did not collect the amount. Therefore, the motion for partial execution did not negate her right to seek reinstatement as the prevailing rule in illegal dismissal cases.
Main Doctrine
The doctrine of strained relations should not be applied indiscriminately to cause the non-reinstatement of a supervisory employee who is dismissed without just cause and without due process by the employer due to an altercation caused by its senior officer who bypassed the dismissed employee. An employee's occupation is his/her means of livelihood, which is a precious economic right; hence, it should not just be taken away from the employee by applying the exception of "strained relations" that is not justified. The State guarantees security of tenure to workers; thus, all efforts must be exerted to protect a worker from unjust deprivation of his/her job.