G.R. No. L-52056 August 10, 1981
Bonifacio De Leon, petitioner, vs. National Labor Relations Commission, Sugar Producers Cooperative Marketing Association, Inc., Alfredo U. Benedicto and Gwendolyn H. Gustilo, respondents.

FACTS

Petitioner Bonifacio De Leon, a managerial employee, was dismissed by respondent Sugar Producers Cooperative Marketing Association, Inc. (SPCMA) following an audit that allegedly uncovered his involvement in financial anomalies. The company asserted that upon being privately confronted by SPCMA President Alfredo Benedicto about these preliminary audit findings, De Leon opted to voluntarily avail of the company’s ongoing retrenchment program and receive his full retirement benefits instead of undergoing a formal investigation. Consequently, he was separated from service.
De Leon, however, filed a complaint for illegal dismissal, contending his termination was without just cause and without due process. The Labor Arbiter ruled in his favor, but the National Labor Relations Commission (NLRC) reversed the decision. The Supreme Court, in its decision dated October 30, 1980, set aside the NLRC ruling and ordered De Leon’s reinstatement with full backwages. The private respondents then filed this motion for reconsideration of that decision.

ISSUE

Whether the motion for reconsideration presents new and compelling reasons to reverse the Supreme Court’s prior decision ordering the reinstatement of petitioner Bonifacio De Leon.

RULING

The Court denied the motion for reconsideration. The arguments raised by the private respondents—that there was no denial of due process, that De Leon voluntarily retired, and that as a managerial employee he could be dismissed for lack of confidence or due to retrenchment—were not new but had already been fully considered and resolved in the main decision. The Court found no compelling reason to disturb its earlier findings.
The legal logic is anchored on the finality of judicial determinations on issues already litigated. The Court reaffirmed that the NLRC failed to substantiate the charges against De Leon with substantial evidence, as a mere generalized statement of his involvement in irregularities was insufficient. Furthermore, the claim of voluntary retirement was deemed inconsistent with human behavior and the factual circumstances; it was illogical for an employee who voluntarily retired to immediately file an illegal dismissal complaint. Since the motion introduced no novel matter that would alter the application of labor law on just cause and due process as previously ruled, the Court upheld its original decision ordering reinstatement and payment of backwages.