GR 115879; (April, 1997) (Digest)
G.R. No. 115879 April 16, 1997
PURE BLUE INDUSTRIES, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and EMPLOYEES OF PURE BLUE INDUSTRIES, INC., represented by SABADO SANTOS, respondents.
FACTS
Petitioner Pure Blue Industries, Inc., an industrial laundry business, terminated the services of private respondents, its machine operators and helpers, on December 27, 1990. Private respondents contended their dismissal was due to their union activities and demands for payment of unpaid thirteenth-month pay and other benefits. They filed a complaint for illegal dismissal and monetary claims on January 3, 1991. Petitioner denied dismissal, claiming financial inability to pay the thirteenth-month pay, and alleged that the employees abandoned their jobs on December 22, 1990, after their pay demands were not met. Petitioner filed a complaint-affidavit for abandonment nearly a month later.
The Labor Arbiter ruled in favor of the employees, ordering reinstatement with full backwages and payment of the thirteenth-month pay. The arbiter found the claim of abandonment illogical, noting the immediate filing of the illegal dismissal case, and concluded the termination was illegal and motivated by the employees’ benefit claims. The NLRC affirmed the decision and denied petitioner’s motion for reconsideration.
ISSUE
Whether the NLRC committed grave abuse of discretion in affirming the Labor Arbiter’s finding that the employees were illegally dismissed and did not abandon their work.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion. The Court emphasized that a petition for certiorari under Rule 65 is limited to correcting jurisdictional errors and that factual findings of administrative agencies like the NLRC, when supported by substantial evidence, are accorded finality and respect. The issue of abandonment is factual, and the Court found the concurrent findings of the Labor Arbiter and the NLRC to be sufficiently grounded.
The Court rejected petitioner’s argument that the employees failed to substantiate their dismissal claim. The employees’ position paper explicitly stated they were terminated after refusing to sign casual employment contracts upon the company’s discovery of their union affiliation. Furthermore, the counter-affidavit of petitioner’s own Vice President revealed that during a dialogue, a financier told the employees “they can leave if they want to,” which they took seriously. This statement undermined the claim of abandonment and supported the finding of dismissal. The immediate filing of the complaint after the New Year celebration negated the intent to abandon, which requires a clear, deliberate, and unjustified refusal to resume work. The dismissal, occurring right after the employees made legitimate benefit demands, was deemed illegal. The award of reinstatement with full backwages was sustained.