GR 80998; (April, 1989) (Digest)
G.R. No. 80998 . April 25, 1989
LEONARDO B. LUCENA, petitioner, vs. PAN-TRADE, INC. and/or Mr. RAMON TY HOAN CHAY and NATIONAL LABOR RELATIONS COMMISSION, respondents.
FACTS
Petitioner Leonardo B. Lucena was employed as a salesman by Pan-Trade, Inc. In November 1983, following a disagreement with the company cashier, who was a niece of the company president Ramon Ty Hoan Chay, Lucena was asked to resign. He refused and continued reporting for work, making several sales thereafter. However, all these sales were disapproved by Ty, and Lucena’s name was eventually removed from the payroll effective January 1, 1984. About a year later, Lucena filed a complaint for illegal dismissal, seeking reinstatement with back wages and moral damages, alleging that his dismissal caused severe financial hardship to his family.
The Labor Arbiter ruled in Lucena’s favor, ordering his reinstatement with full back wages and awarding him P50,000.00 in moral damages. On appeal, the National Labor Relations Commission (NLRC) modified the decision, deleting the award of reinstatement and moral damages, and instead ordering the payment of separation pay. Lucena filed a motion for reconsideration with the Supreme Court, which initially dismissed his petition for failure to show grave abuse of discretion by the NLRC. He then filed the instant motion for reconsideration.
ISSUE
Whether the NLRC committed grave abuse of discretion in modifying the Labor Arbiter’s decision by deleting the award of reinstatement and moral damages.
RULING
The Supreme Court partially granted the motion for reconsideration. The Court affirmed the NLRC’s finding of illegal dismissal but modified its ruling on the remedies awarded. On the issue of reinstatement, the Court upheld the NLRC’s substitution of separation pay. The Court agreed with the private respondents that the employer-employee relationship had been severely strained, as the employers were adamantly opposed to Lucena’s return. Citing the employer’s prerogative to maintain a harmonious workplace, the Court held that forced reinstatement of an unwanted employee would be counterproductive and detrimental to industrial peace.
However, the Court reversed the NLRC on the issue of moral damages. The Court found that the dismissal was effected in an oppressive manner, stemming from a minor quarrel with a relative of the president, constituting a clear abuse of the employer’s authority. This unjust act warranted an award for moral damages to compensate for the resulting mental anguish, humiliation, and financial dislocation suffered by Lucena. While the Court found the original award of P50,000.00 excessive due to insufficient proof for the full claimed injuries, it exercised its discretion to award a reduced amount of P25,000.00 as reasonable moral damages. Thus, the challenged NLRC decision was affirmed with the modification that moral damages be awarded to the petitioner.