GR 116462; (October, 1995) (Digest)
G.R. No. 116462 October 18, 1995
Reno Foods, Inc., petitioner, vs. National Labor Relations Commission and Noel Cantonjos, respondents.
FACTS
Petitioner Reno Foods, Inc. employed private respondent Noel Cantonjos as a utility worker. On January 2, 1990, Cantonjos was allegedly verbally informed by the company manager, Antonio Ong, that his employment was terminated effective the next day. Despite pleas from his parents, who were also employees, he was not allowed to return to work. The company, however, claimed that Cantonjos had abandoned his job by failing to report for work starting January 2, 1990. Cantonjos filed a complaint for illegal dismissal only on June 18, 1992, or two years and five months after the alleged dismissal. The Labor Arbiter initially dismissed the complaint but, upon remand by the NLRC for further proceedings, reversed himself and ordered Cantonjos’s reinstatement without back wages. The NLRC affirmed this decision.
ISSUE
Whether the NLRC committed grave abuse of discretion in affirming the Labor Arbiter’s decision ordering the reinstatement of Cantonjos despite the alleged abandonment and the delay in filing the complaint.
RULING
The Supreme Court dismissed the petition and affirmed the NLRC decision. The Court held that the findings of the NLRC, which affirmed the Labor Arbiter’s factual conclusion that Cantonjos was illegally dismissed, are generally conclusive and binding if supported by substantial evidence. The company’s defense of abandonment failed because it did not comply with the twin requirements of showing a clear and deliberate intent to sever the employment relationship and serving a notice to the employee. Mere absence is not abandonment. The company’s claim that it had a standing procedure to formally address dismissals and abandonments was insufficient to overturn Cantonjos’s positive assertion of dismissal, which was supported by his and his parents’ testimonies. Regarding the delay, the Court ruled that the complaint, filed within three years from dismissal, was within the prescriptive period. Laches could not be invoked absent convincing evidence of deliberate inaction, especially in labor cases where the constitutional policy of social justice favors the protection of workers’ rights. However, Cantonjos’s claim for back wages was denied as he failed to properly appeal that specific issue, allowing that portion of the decision to become final.