GR 245344; (December, 2020) (Digest)
G.R. No. 245344 , December 02, 2020
DEL MONTE LAND TRANSPORT BUS COMPANY AND NARCISO O. MORALES, PETITIONERS, VS. CARLITO T. ABERGOS, RESPONDENT.
FACTS
Respondent Carlito Abergos, a bus driver for petitioner Del Monte Land Transport Bus Company (DLTB), was suspended and subsequently dismissed following an incident at Matnog Port concerning passenger ferry arrangements. Abergos filed a complaint for illegal dismissal. The Labor Arbiter (LA) ruled in his favor, declaring the dismissal illegal and awarding backwages, separation pay in lieu of reinstatement, and attorney’s fees. Petitioners did not appeal this decision. Abergos, however, filed a partial appeal before the National Labor Relations Commission (NLRC) contesting the award of separation pay and seeking reinstatement.
The NLRC granted Abergos’s appeal, deleting the separation pay and ordering his reinstatement. Petitioners then filed a motion for reconsideration with the NLRC, arguing for the first time that reinstatement was inappropriate due to alleged strained relations, and submitted evidence of Abergos’s past infractions and alleged arrogant behavior. The NLRC reversed itself, finding the existence of strained relations and reinstating the award of separation pay. The Court of Appeals (CA) later reversed the NLRC, ruling that the evidence of strained relations was belatedly submitted and that Abergos was entitled to reinstatement.
ISSUE
Whether the NLRC committed grave abuse of discretion in receiving and considering the belatedly submitted evidence on strained relations to justify the award of separation pay in lieu of reinstatement.
RULING
The Supreme Court ruled that the NLRC did not commit grave abuse of discretion. The Court emphasized that technical rules of procedure are not strictly applied in labor cases to serve the demands of substantial justice. While petitioners failed to submit their position paper and evidence before the LA, they timely raised the issue of strained relations and submitted supporting evidence in their motion for reconsideration of the NLRC’s initial reinstatement order. This submission was made at the first opportunity to contest the specific remedy of reinstatement, as the LA’s original decision awarding separation pay had not been appealed by petitioners and was thus final as to that liability.
The NLRC’s factual finding of strained relations, based on substantial evidence including multiple incident reports of Abergos’s infractions and conduct towards passengers and superiors, was upheld. The existence of such strained relations makes reinstatement impracticable, warranting the award of separation pay. The CA erred in disallowing this evidence on purely procedural grounds. The Petition was granted, reversing the CA and reinstating the NLRC resolution which awarded separation pay.