G.R. No. 79496 November 19, 1991
SOLID ENGINEERING & MACHINE WORKS, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and LUIS LOPEZ, respondents.

FACTS

Luis Lopez, a field representative and salesman for Solid Engineering & Machine Works (SOLID) since 1973, was granted a one-month leave of absence from August 1 to 31, 1984, for a medical check-up and rest. During this approved leave, SOLID discovered that Lopez sought and obtained employment with its competitor, Asian Engine Rebuilders, Inc., on August 16, 1984. Evidence showed his new employer reported him to the SSS on August 27, 1984, he used calling cards from the new company, and he actively solicited SOLID’s clients to transfer their business. After his leave expired, Lopez failed to report for work. SOLID filed an application for clearance to terminate his employment on September 5, 1984, on the ground of abandonment.
Lopez later filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, ordering reinstatement with full backwages and damages. The National Labor Relations Commission (NLRC) affirmed but modified the award, reducing back wages to one year. Both lower tribunals concluded Lopez was illegally dismissed, finding it unnatural for him to abandon a decade-long job.

ISSUE

Whether the NLRC committed grave abuse of discretion in ruling that Lopez was illegally dismissed, thereby ignoring uncontroverted evidence of abandonment and breach of trust.

RULING

Yes. The Supreme Court granted the petition for certiorari, reversing the NLRC. The legal logic is anchored on the principle that factual findings of the NLRC are generally respected, but they may be overturned when they result from a grave abuse of discretion, such as ignoring or disregarding substantial evidence. Here, SOLID presented unrebutted evidence—SSS coverage by a competitor, distribution of new calling cards, and pirating of clients—all occurring during Lopez’s leave. This evidence conclusively established that Lopez voluntarily abandoned his employment and engaged in disloyal conduct constituting breach of trust, both valid grounds for dismissal under labor laws.
The NLRC’s reliance on the mere assumption that abandoning a long-tenured job was “unnatural” constituted a capricious disregard of proven facts. Since the employer’s evidence stood uncontradicted, the legal presumption of abandonment remained unrebutted. Consequently, the dismissal was for just cause, and SOLID incurred no liability. The Court held that certiorari was proper to correct such a grave abuse of discretion, which rendered the NLRC’s decision devoid of rational basis.