GR 115759; (June, 1996) (Digest)
G.R. No. 115759 June 21, 1996
PURIFICACION F. RAM, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and JRS BUSINESS CORPORATION, respondents.
FACTS
Petitioner Purificacion F. Ram was employed by private respondent JRS Business Corporation as a counter-clerk trainee on June 11, 1991. On August 26, 1991, she received an inter-office memorandum appointing her as a probationary employee for six months. Before the probationary period concluded, JRS terminated her services on February 15, 1992, citing unsatisfactory performance and various alleged violations of company rules. Ram filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, ordering reinstatement with full backwages and attorney’s fees.
On appeal, the National Labor Relations Commission (NLRC) affirmed the finding of illegal dismissal and the order for reinstatement. However, it modified the Labor Arbiter’s decision by deleting the awards of backwages and attorney’s fees. The NLRC justified the denial of backwages by characterizing Ram’s dismissal as based on a mere “technicality,” implying the employer’s failure to follow proper procedure rather than a complete absence of cause. Ram’s motion for reconsideration was denied.
ISSUE
Whether the NLRC committed grave abuse of discretion in deleting the award of backwages and attorney’s fees despite its finding that the petitioner was illegally dismissed.
RULING
Yes. The Supreme Court found that the NLRC committed grave abuse of discretion. The legal logic is clear and sequential. First, a finding of illegal dismissal legally entitles the employee to two primary reliefs: reinstatement and payment of backwages. This is a settled doctrine under Article 279 of the Labor Code. The award of backwages is not discretionary; it is a mandatory consequence intended to make the employee whole for the income lost due to the unlawful termination.
Second, the NLRC’s rationale for deleting backwages—that the dismissal was based on a “technicality”—is legally erroneous. The Court clarified that an illegal dismissal is precisely that: a termination effected without a valid or authorized cause and without due process. The absence of either substantive or procedural due process renders the dismissal illegal. The characterization of the flaw as a “technicality” does not negate the illegality. Since the NLRC itself sustained the Labor Arbiter’s finding of illegal dismissal, it had no legal basis to withhold the statutory award of backwages. Consequently, the Supreme Court reinstated the Labor Arbiter’s award of backwages and attorney’s fees. However, it denied Ram’s separate claim for “payroll backwages” during the appeal period, reiterating that such relief requires a writ of execution and is not self-executory.