G.R. No. L-53721. June 29, 1982.
PAN-PHILIPPINE LIFE INSURANCE CORPORATION (Formerly Cardinal Life Insurance Corporation), petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and LUCIO G. ANGELES, JR., respondents.

FACTS

Lucio G. Angeles, Jr. was employed by Cardinal Life Insurance Corporation (later Pan-Philippine Life) in 1966 as an accountant. He was later promoted, and in March 1973, the board of directors elected him as a corporate vice-president with a corresponding salary increase. A central dispute arose regarding whether Angeles held a dual role as both chief accountant and vice-president concurrently, or solely the managerial position of vice-president. In March 1977, the board did not reelect him as vice-president. The corporation subsequently notified him that he was no longer connected with the company, effectively terminating his employment.
Angeles filed a complaint for illegal dismissal and payment of separation pay. Initially ambiguous, he later clarified his theory, asserting he held two distinct positions: vice-president and chief accountant. He contended that while he accepted his non-reelection as vice-president, his simultaneous dismissal from the position of accountant was illegal as it lacked just cause. The corporation argued he held only the elective corporate office of vice-president, the termination of which was a valid prerogative of the board.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in ordering the reinstatement of Lucio G. Angeles, Jr. to the position of chief accountant with backwages.

RULING

The Supreme Court dismissed the petition, affirming the NLRC’s decision. The Court held it was bound by the factual findings of the labor arbiter and the NLRC, which were supported by documentary evidence, that Angeles indeed functioned in a dual capacity as both chief accountant and vice-president. The legal logic is that factual determinations of administrative agencies like the NLRC, when supported by substantial evidence, are accorded respect and finality. The non-reelection to the corporate office of vice-president was a valid termination of that managerial function. However, this act did not constitute a legal or valid cause for the simultaneous termination of his separate, non-elective position as a rank-and-file chief accountant. Since no just cause was shown for dismissing him from his accountant role, that dismissal was illegal.
Consequently, the order for reinstatement to the position of chief accountant was upheld. However, the computation of backwages was clarified. As his dismissal from the vice-presidency was valid, backwages could only be based on the salary attributable to his position as accountant (P800 monthly plus transportation allowance) from the date of his illegal dismissal, not on his total combined compensation from both positions. The NLRC did not commit grave abuse of discretion in its ruling.