GR 154985; (August, 2004) (Digest)
G.R. No. 154985 ; August 24, 2004
KAR ASIA, INC. and/or CELESTINO S. BARETTO, petitioners, vs. MARIO CORONA, et al., respondents.
FACTS
Respondents, regular employees of petitioner KAR ASIA, Inc., filed a complaint for underpayment of wages, specifically claiming non-payment of their Cost of Living Allowance (COLA) for December 1993 and December 1994 as mandated by the applicable Wage Order. Petitioners countered that the COLA had been paid and presented payrolls for the contested periods. The Labor Arbiter dismissed the complaint and ordered the employees to pay damages and attorney’s fees to the employer. The NLRC affirmed but deleted the monetary awards against the employees. On appeal via certiorari, the Court of Appeals reversed the NLRC, ordering the payment of the December 1994 COLA plus interest. The appellate court held the payrolls for December 1994 were insufficient evidence of payment as they lacked the employees’ acknowledging signatures, appearing merely to be copies approved for payment rather than proof of actual disbursement.
ISSUE
Whether the Court of Appeals erred in finding that petitioners failed to substantiate payment of the December 1994 COLA to the respondents.
RULING
Yes, the Supreme Court reversed the Court of Appeals and reinstated the NLRC decision dismissing the claims. The legal logic centers on the standard of proof in labor cases and the respect accorded to factual findings of quasi-judicial agencies. The Court held that while the December 1994 payrolls lacked employee signatures, the signed payslips for the same period, which contained an acknowledgment by the employees of having received full compensation for services rendered, constituted substantial evidence of payment. There is no rigid rule that only a signed payroll can prove payment; a signed payslip acknowledging full receipt can serve the same purpose. The Court of Appeals erred in disregarding this evidence and in re-evaluating the factual findings of the NLRC, which are generally accorded finality when supported by substantial evidence. Since the petition before the CA was one for certiorari under Rule 65, its review should have been confined to determining jurisdictional errors or grave abuse of discretion, not to reassessing the weight of the evidence. The NLRC committed no grave abuse of discretion in finding the payslips sufficient to establish payment.