G.R. No. 213488. November 07, 2016.
TOYOTA PASIG, INC., PETITIONER, VS. VILMA S. DE PERALTA, RESPONDENT.

FACTS

Respondent Vilma S. De Peralta was a long-time employee of petitioner Toyota Pasig, Inc., eventually rising to the position of Insurance Sales Executive (ISE). Her employment was terminated in February 2012 following a charge of dishonesty. The company alleged she processed insurance for three vehicle units from the dealership’s own inventory as “outside transactions” to claim personal commissions, instead of crediting them as “new business accounts” belonging to the marketing department. Respondent filed a complaint for illegal dismissal and monetary claims, including unpaid commissions, tax rebates, and profit sharing from July 2011 to January 2012 totaling ₱617,248.08. She also alleged her dismissal was in retaliation for her husband’s union activities. The Labor Arbiter (LA) found the dismissal for serious misconduct valid but ordered payment of her January 2012 salary, dismissing her other monetary claims for lack of proof.
On appeal, the National Labor Relations Commission (NLRC) affirmed the legality of the dismissal. However, it reversed the LA on the monetary claims, holding petitioner liable for the full ₱617,248.08. The NLRC ruled that while termination was justified, respondent’s claims for earned commissions and benefits were separate from the dismissal issue. It emphasized that petitioner failed to present evidence, such as payroll records or proof of payment, to rebut respondent’s computations and substantiate that these benefits were not due. The Court of Appeals affirmed the NLRC’s ruling in toto.

ISSUE

Whether the NLRC committed grave abuse of discretion in awarding respondent her monetary claims for unpaid commissions and benefits despite finding her dismissal for just cause.

RULING

The Supreme Court denied the petition and affirmed the award. The legal logic rests on the distinct nature of a claim for illegal dismissal and a claim for unpaid wages or earned benefits. A finding of valid dismissal absolves the employer from paying backwages and separation pay. However, it does not extinguish the obligation to pay compensation already earned by the employee prior to termination, such as commissions, allowances, and profit-sharing that had accrued through work performed. The burden of proof for these monetary claims shifts under labor law.
Following the rule in Mabeza v. NLRC, if an employee alleges non-payment of wages or benefits, the employer has the affirmative duty to prove payment was made. If the employer fails to present pertinent records like payrolls, the employee’s claim, supported by credible evidence, may be granted. Here, respondent submitted computations for her claims. Petitioner, despite being given the opportunity, did not present company records to disprove these claims or show that the benefits had been paid. Its failure to do so gave rise to the presumption that such evidence would be adverse to its case. Consequently, the NLRC correctly held that respondent, though legally dismissed, was still entitled to receive the monetary benefits she had already earned. No grave abuse of discretion attended this finding.