Cornworld Breeding Systems v. Alvaro-Ladia
REITERATIONFacts
The Antecedents: Lucena M. Alvaro-Ladia was employed by Cornworld Breeding Systems Corporation (Cornworld) in August 1982, rising to the position of Vice President for Research and Development. In January 2009, following a stroke suffered by the company's president, Laureano C. Domingo assumed management. Shortly thereafter, during a meeting, Laureano allegedly berated Lucena, leading to a heated exchange where Lucena pleaded to be treated with dignity and was subsequently told to leave the premises. This incident caused Lucena to be hospitalized for hypertension. She subsequently filed for sick leave and later sought payment for her salary and incentives. The company then issued a memorandum appointing an Overseer for the Research and Development department, which Lucena perceived as rendering her position redundant and her employment in a floating status. She also claimed to have received threats and was unable to attend a company meeting, as others were sent in her stead. Consequently, Lucena filed a complaint for constructive dismissal. Procedural History: The Labor Arbiter dismissed Lucena's complaint for illegal dismissal. Upon appeal, the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision, finding neither constructive dismissal nor abandonment of work, and denying Lucena's motion for reconsideration. Lucena then filed a Petition for Certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the NLRC. The CA granted her petition, setting aside the NLRC's decision and ordering Cornworld to pay Lucena backwages, separation pay, and attorney's fees. Cornworld moved for reconsideration, which the CA denied. This led to Cornworld filing the instant Petition for Certiorari with the Supreme Court. The Petition: Cornworld filed a Petition for Certiorari under Rule 65 of the Rules of Court, assailing the CA's decision and resolution. They argued that the CA gravely abused its discretion, that they did not dismiss Lucena, that Lucena abandoned her job, and that she was afforded due process. The Supreme Court initially dismissed the petition for being the wrong mode of appeal and for failing to comply with procedural requirements. However, upon reconsideration, the Court treated the petition as a Rule 45 Petition for Review on Certiorari but found it was filed out of time. Despite the procedural infirmities, the Court reviewed the merits and found that Cornworld constructively dismissed Lucena. The Court held that Cornworld failed to prove abandonment and that the circumstances, including the appointment of an overseer, withholding of salaries, and public humiliation, made Lucena's continued employment impossible and unbearable, thus constituting constructive dismissal. The petition was ultimately dismissed, and the CA's decision was affirmed.
Issue(s)
Whether the Supreme Court should treat Cornworld's Petition for Certiorari as a Petition for Review on Certiorari, and whether Cornworld's Petition for Certiorari was filed within the reglementary period. Whether Cornworld constructively dismissed Lucena. Whether Lucena abandoned her work. Whether Cornworld's assertion of loss of trust and confidence as a ground for dismissal was substantiated, and the propriety of monetary awards.
Ruling
The Supreme Court dismissed the Petition for Certiorari. It held that Cornworld availed of the wrong remedy and filed the petition late. Even if treated as a Petition for Review on Certiorari, it was filed beyond the 15-day reglementary period. Furthermore, the Court found that the Court of Appeals did not gravely abuse its discretion in ruling that Lucena was constructively dismissed. The Court affirmed the CA's Decision and Resolution.
Ratio Decidendi
On the propriety of the remedy and timeliness of the petition: The Court reiterated that a Petition for Certiorari under Rule 65 is an original action limited to grave abuse of discretion, while a Petition for Review on Certiorari under Rule 45 is a mode of appeal for questions of law. Certiorari cannot substitute for a lost appeal. Although the Court may, in the interest of substantial justice, treat a Rule 65 petition as a Rule 45 petition, this is not possible when the petition is filed beyond the reglementary period. In this case, Cornworld received the CA's Resolution denying its motion for reconsideration on August 1, 2012, and filed its petition on September 28, 2012, which is 58 days late, far exceeding the 15-day period for a Rule 45 petition. Additionally, the petition suffered from procedural infirmities, including the lack of proof of service. On constructive dismissal: The Court found that Cornworld constructively dismissed Lucena. This was evidenced by the appointment of an overseer that rendered her position in a "floating status," the withholding of her salaries and benefits while she was on leave, and the public ridicule and humiliation she endured, which made her continued employment impossible and unbearable. On abandonment: The Court disagreed with Cornworld's contention that Lucena abandoned her work. Abandonment requires a clear intention to sever the employer-employee relationship, manifested by overt acts, and the burden of proof rests on the employer. Lucena's filing of sick leave applications and her immediate filing of an illegal dismissal complaint negated any intention to abandon her job. On loss of trust and confidence and monetary awards: Cornworld's assertion of loss of trust and confidence as a ground for dismissal was found to be unsubstantiated. To justify termination on this ground, the employer must show that the employee holds a position of trust and confidence and must establish a real, founded act justifying the loss of trust, which must be willful, intentional, and done without justifiable excuse. Cornworld failed to prove that Lucena's alleged breach of trust was willful or done without justifiable excuse. In cases of illegal dismissal, employees are entitled to backwages and reinstatement. However, when reinstatement is no longer feasible, separation pay is granted in lieu thereof. The Court affirmed the CA's award of full backwages, separation pay, and attorney's fees.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' finding that the employee was constructively dismissed, holding that the employer failed to prove abandonment of work and that the circumstances rendered the employee's continued employment impossible and unbearable. The Court also dismissed the employer's petition for certiorari due to the wrong mode of appeal and late filing.