G.R. No. 114337 September 29, 1995
NITTO ENTERPRISES, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and ROBERTO CAPILI, respondents.

FACTS

Petitioner Nitto Enterprises hired Roberto Capili on May 28, 1990, under an apprenticeship agreement for six months. On August 2, 1990, Capili accidentally injured a secretary while handling glass. Later that same day, after office hours, he entered a workshop not assigned to him and operated a power press machine without authorization, injuring his own thumb. The company paid for his medical treatment. The following day, Capili was presented with and signed a letter detailing the incidents and requesting his resignation. On August 3, 1990, he executed a Quitclaim and Release in exchange for a sum of money.
Three days later, on August 6, 1990, Capili filed a complaint for illegal dismissal. The Labor Arbiter ruled the dismissal valid, citing gross negligence and improper attitude. The National Labor Relations Commission (NLRC) reversed this decision, declaring Capili a regular employee entitled to security of tenure and finding his dismissal illegal. The NLRC also found the apprenticeship agreement invalid as it was filed with the Department of Labor only on June 7, 1990, after his hiring on May 28, 1990.

ISSUE

Whether the NLRC committed grave abuse of discretion in: (1) holding that private respondent was not an apprentice but a regular employee; and (2) holding that petitioner failed to prove a valid cause for termination.

RULING

The Supreme Court upheld the NLRC’s decision, finding no grave abuse of discretion. On the first issue, the Court affirmed that Capili was a regular employee. The apprenticeship agreement, filed only on June 7, 1990, could not validly govern his employment which began on May 28, 1990. Consequently, he was deemed a regular employee under Article 280 of the Labor Code from his start date, entitled to constitutional security of tenure.
On the second issue, the Court found the dismissal illegal for lack of due process. The employer failed to comply with the twin-notice requirement. Capili was summarily presented with a pre-written resignation letter and a quitclaim immediately after the incidents. His filing of an illegal dismissal complaint just three days later indicated the resignation was not voluntary. The employer orchestrated these documents to disguise a summary dismissal, violating the employee’s right to be heard and to defend himself. Therefore, the termination was void. The NLRC correctly ordered reinstatement with backwages.