G.R. No. L-72588 October 15, 1986
JORGE W. JOSE, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, AGUINALDO DEVELOPMENT CORPORATION and JOSE G. RICAFORT, respondents.

FACTS

Petitioner Jorge W. Jose began employment with Daniel R. Aguinaldo Corporation (DRACOR) in 1956. In July 1975, via a company memo, he was formally transferred to Aguinaldo Development Corporation (ADECOR), with ADECOR expressly assuming his seniority and benefits accrued from his DRACOR service. In July 1976, a new management group led by respondent Jose G. Ricafort took over ADECOR. By a memo dated January 31, 1978, ADECOR’s Chairman, Daniel R. Aguinaldo, confirmed petitioner’s official retirement as of December 31, 1977, and directed Ricafort to pay his retirement gratuity, unpaid salaries, and accrued leave benefits. ADECOR and Ricafort refused payment, prompting Jose to file a complaint.
The Labor Arbiter initially ruled in Jose’s favor, finding an employer-employee relationship with ADECOR based on the transfer memo, retirement memo, and other corroborating documents. Private respondents, however, moved for reconsideration and succeeded in having the case reheard. Through a series of motions seeking the inhibition of multiple Labor Arbiters, they delayed proceedings for years. Eventually, a fourth Labor Arbiter reversed the initial decision, dismissing the complaint for lack of employer-employee relationship. The NLRC affirmed this dismissal.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the dismissal of petitioner’s complaint for monetary claims based on a finding of no employer-employee relationship.

RULING

Yes. The Supreme Court annulled the NLRC’s decision, finding it was rendered with grave abuse of discretion. The legal logic rests on the conclusive evidence establishing Jose’s employment with ADECOR, which the NLRC arbitrarily ignored. The July 1, 1975 memo was an unambiguous written instrument effecting his transfer from DRACOR to ADECOR as his new employer, with an explicit assumption of his tenure and benefits. This document alone prima facie established the relationship. This was corroborated by the January 31, 1978 retirement memo from ADECOR’s Chairman, which not only confirmed Jose’s status as an ADECOR executive but also unequivocally acknowledged the corporation’s obligation to pay his retirement and other benefits. The NLRC’s failure to accord these clear, contemporaneous, and uncontroverted company documents any evidentiary weight constituted a capricious and whimsical disregard of evidence, which is a hallmark of grave abuse of discretion. The Court also noted that private respondents’ procedural tactic of repeatedly seeking the inhibition of Labor Arbiters was a transparent scheme to delay the resolution of the case, further underscoring the unreasonableness of the NLRC’s ultimate ruling. Consequently, the Court reinstated the original Labor Arbiter’s decision awarding Jose his claims.