G.R. No. 168096 ; August 28, 2007
ALEX B. CARLOS, ABC SECURITY SERVICES, INC., and HONEST CARE JANITORIAL SERVICES, INC., Petitioners, vs. COURT OF APPEALS, PERFECTO P. PIZARRO, JOEL B. DOCE, GUILLERMO F. SOLOMON, FRANCISCO U. CORPUS and RONILLO GALLEGO, Respondents.

FACTS

Petitioners ABC Security Services, Inc. and Honest Care Janitorial Services, Inc., represented by their president Alex B. Carlos, are job contractors providing security and janitorial services. Private respondents were employees: Pizarro, Doce, Corpus, and Gallego as security guards for ABC Security, and Solomon as a janitor supervisor for Honest Care. On July 22, 1993, private respondents filed a complaint against petitioners for various monetary claims, including underpayment of wages and non-payment of benefits. Petitioners received the summons on July 16, 1993. Shortly thereafter, the private respondents were relieved from their posts and not given new assignments, which they alleged constituted illegal dismissal.
Petitioners countered that the employees voluntarily resigned, as evidenced by signed resignation letters, after refusing reassignments following the end of their assignment at Greenvalley Country Club. They also claimed the resignations were prompted by the employees’ liability for lost bowling equipment. The Labor Arbiter initially dismissed the complaint, crediting petitioners’ documentary evidence like payrolls and resignation letters.

ISSUE

Whether the Court of Appeals correctly affirmed the NLRC’s finding that the private respondents were illegally dismissed.

RULING

Yes, the Supreme Court affirmed the Court of Appeals’ decision. The legal logic centered on the burden of proof in dismissal cases and the evaluation of evidence. In termination disputes, the employer bears the burden to prove that the dismissal was for a just or authorized cause. Here, petitioners failed to discharge this burden convincingly. The Court found the purported resignation letters dubious, as they were unverified and the circumstances suggested coercion, especially given the timing—the employees were dismissed immediately after petitioners received the labor complaint. This sequence created a presumption that the dismissal was retaliatory.
The NLRC and the Court of Appeals correctly gave greater weight to the consistent testimonies of the private respondents regarding their forced resignations and the practice of signing dual pay slips (one in ink, one in pencil), which indicated possible wage manipulation. Petitioners’ payroll records were deemed insufficient to overturn these factual findings. The Supreme Court emphasized that factual findings of quasi-judicial agencies, when supported by substantial evidence, are accorded respect and finality. Thus, the finding of illegal dismissal, making petitioners jointly and severally liable for backwages, separation pay, and other monetary awards, was upheld. The computation of backwages was modified to run from dismissal until the finality of the Court’s judgment.