G.R. No. 189229 , November 23, 2015
REYNALDO NOBLADO, ET AL., PETITIONERS, VS. PRINCESITA K. ALFONSO, RESPONDENT.

FACTS

Petitioners were employees of respondent Princesita K. Alfonso, an independent contractor operating “Cherry Alfonso Plant Nursery,” hired as gardeners, landscapers, laborers, and a driver. They filed complaints for illegal dismissal in January and February 2001, alleging they were not paid various statutory benefits and were abruptly terminated on January 15, 2001, without valid cause and due process. Respondent contended petitioners were contractual workers whose employment was dependent on her contract with Sta. Lucia Realty Development, Inc., and that they were dismissed for cause due to deliberate work stoppage, serious misconduct, and gross neglect, which led Sta. Lucia to cancel its contract with her. The Labor Arbiter ruled in favor of petitioners, finding illegal dismissal and ordering reinstatement with full backwages and payment of monetary benefits. The NLRC affirmed the Labor Arbiter’s decision. The Court of Appeals partially granted respondent’s appeal, setting aside the award of backwages and instead ordering respondent to pay each petitioner ₱10,000.00 as nominal damages for procedural due process violation, while affirming the awards for service incentive leave pay and 13th month pay. The CA found petitioners voluntarily abandoned their work, constituting a just cause for dismissal, but held respondent failed to comply with the notice requirement.

ISSUE

Whether petitioners were illegally dismissed from their employment.

RULING

No. The Supreme Court held that petitioners were dismissed for a just cause but without due process. The Court found that petitioners’ deliberate and concerted refusal to work, which resulted in the cancellation of respondent’s contract with Sta. Lucia, constituted gross neglect of duties and willful disobedience, which are just causes for termination under Article 282 of the Labor Code. However, respondent failed to comply with the twin-notice requirement and a hearing, thereby violating petitioners’ right to procedural due process. Consequently, while the dismissal was for a just cause, the absence of due process entitled petitioners to nominal damages. The Court modified the CA decision, increasing the nominal damages from ₱10,000.00 to ₱30,000.00 each, in line with prevailing jurisprudence. The awards for service incentive leave pay and 13th month pay were affirmed. The Court also upheld the validity of the Affidavits of Desistance and Quitclaims executed by 11 of the original complainants, finding them to be voluntary and made with full understanding.