GR 140102; (February, 2006) (Digest)
G.R. No. 140102 , February 9, 2006
UNION INDUSTRIES, INC., Petitioner, vs. GASPAR VALES and PRUDENCIO CERDENIA, Respondents.
FACTS
Respondents Gaspar Vales and Prudencio Cerdenia were agency workers assigned to petitioner Union Industries, Inc. as carpenters since 1983 and 1986, respectively. In 1995, a grievance meeting led to a compromise agreement for their regularization. The agreement stipulated that their prior years of service under the agency would be “tacked in” for purposes of retirement or separation pay only. Upon regularization, they were diagnosed with pulmonary tuberculosis (PTB) but were allowed to work for another year subject to re-examination. In June 1996, they were again found positive for PTB and were required to go on sick leave. Instead, they filed a complaint for illegal dismissal.
The Labor Arbiter dismissed the illegal dismissal complaint, finding they were merely placed on sick leave. However, the Arbiter awarded separation benefits, computing the benefits from the date they were first assigned to petitioner in the 1980s, not from the 1995 regularization agreement, based on equity. The National Labor Relations Commission (NLRC) affirmed this decision.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for certiorari and upholding the NLRC’s award of separation benefits computed from respondents’ first assignment to petitioner.
RULING
The Supreme Court denied the petition and upheld the Court of Appeals. The dismissal of the certiorari petition was proper due to petitioner’s procedural failure to attach pertinent pleadings, violating Rule 65. While rules of procedure are not to be applied rigidly at the cost of justice, they cannot be ignored without persuasive reason, as their observance is essential for the orderly resolution of issues.
On the substantive award, the Court affirmed the computation of separation benefits from the start of respondents’ assignment in the 1980s. Factual findings of the Labor Arbiter, when affirmed by the NLRC and the Court of Appeals, are generally binding and conclusive on the Supreme Court. The Court’s jurisdiction in a Rule 45 petition is limited to reviewing errors of law, not re-examining evidence. The labor tribunals’ determination, grounded in equity and the social justice principles of labor law, that the entire period of service should be credited for separation pay, stands.