G.R. No. 241445 , August 14, 2019
REY BEN P. MADRIO, Petitioner, vs. ATLAS FERTILIZER CORPORATION, Respondent.

FACTS

Petitioner Rey Ben P. Madrio was the Area Sales Manager of respondent Atlas Fertilizer Corporation (AFC) from 2008 until he tendered his resignation in November 2015. Upon resigning, he requested payment of several monetary benefits, including separation pay under AFC’s purported retirement/separation policy. AFC did not act on his request. Madrio filed a complaint for monetary claims, attaching an unsigned and unauthenticated copy of a Retirement Plan as evidence of his entitlement to separation benefits.
AFC opposed the claim, denying that the submitted document was its official policy. It argued that Madrio was not entitled to any separation benefit because he had caused the company a massive financial loss due to gross negligence in handling uncollected receivables, constituting a derogatory record. The Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in Madrio’s favor, awarding separation pay. The NLRC, while noting Madrio was ineligible for retirement, held he was entitled to separation benefits under the Plan’s provision for voluntary resignation without a derogatory record, reducing the awarded amount.

ISSUE

Whether the NLRC gravely abused its discretion in admitting the unsigned and unauthenticated Retirement Plan as evidence and consequently awarding separation benefits to Madrio.

RULING

The Supreme Court ruled in the negative, reinstating the NLRC’s award of separation benefits. The Court clarified that in a petition for review under Rule 45, it reviews the legal correctness of the Court of Appeals’ (CA) decision. The CA erred in applying strict rules of evidence to nullify the NLRC’s factual findings. Labor tribunals are not bound by technical rules of procedure, and the NLRC acted within its discretion in admitting the document, especially since AFC failed to present its own official policy to rebut it.
The legal logic centers on the principle of estoppel and the burden of proof. AFC’s March 20, 2016 reply-letter, submitted during proceedings, indicated Madrio’s benefits were being processed, which the NLRC correctly interpreted as a tacit admission of the existence of a separation policy and Madrio’s potential entitlement. As the employer, AFC possessed the records and had the burden to prove the policy’s non-existence or that Madrio was disqualified. By failing to present the authentic company policy and merely denying the submitted copy, AFC did not discharge this burden. The claim of a derogatory record due to alleged gross negligence was an unsubstantiated allegation. Consequently, the NLRC did not commit grave abuse of discretion; its decision was supported by substantial evidence. The award of separation pay was proper.