GR L 55703; (November, 1986) (Digest)
G.R. No. L-55703 November 27, 1986
PHILIPPINE OVERSEAS DRILLING AND OIL DEVELOPMENT CORPORATION, petitioner, vs. THE HON. MINISTRY OF LABOR, HON. FRANCISCO L. ESTRELLA, Regional Director, Region IV, Ministry of Labor and Employment, MARIANO M. MELENDRES, JR., and Sheriffs ABE ESTRADA and PERCIVAL GRANADO, respondents.
FACTS
Petitioner Philippine Overseas Drilling and Oil Development Corporation (PODODC) is a domestic corporation. Private respondent Mariano M. Melendres, Jr., employed as Chief Geologist since 1969, tendered his irrevocable resignation effective September 29, 1979. On November 20, 1979, he inquired about his separation benefits, referencing a company policy granting such pay to resigning employees. Instead of replying, PODODC filed an application for clearance to terminate his employment due to resignation. Melendres filed a complaint/opposition, alleging unfair labor practice for the refusal to grant separation pay.
The case was heard by respondent Regional Director Francisco L. Estrella. Based on the records, including documentary evidence presented by Melendres showing payments to other similarly situated employees, the Regional Director issued an Order on August 7, 1980, directing PODODC to pay Melendres termination benefits of one month’s pay for every year of service, totaling P67,400.00, pursuant to company policy. PODODC received notice on August 13, 1980, but filed a “Motion for Reconsideration and/or Appeal” only on December 10, 1980, well beyond the reglementary period. A writ of execution had already been issued on November 28, 1980.
ISSUE
Whether the Regional Director committed grave abuse of discretion in awarding separation pay to a voluntarily resigning employee based on an alleged company policy.
RULING
The Supreme Court dismissed the petition. On procedural grounds, the Court found that PODODC was estopped from questioning the Regional Director’s jurisdiction. By participating in the proceedings without raising the jurisdictional issue at the earliest opportunity and by filing a motion for reconsideration before the same office, PODODC voluntarily submitted to its authority. The belated challenge was barred.
On the substantive merits, the Court held that the Regional Director did not commit grave abuse of discretion. The finding of a company policy to grant separation benefits was supported by substantial evidence—specifically, documentary exhibits presented by Melendres. Administrative agencies’ factual findings, especially those of labor officials with expertise, are accorded respect and finality if supported by substantial evidence. The Court emphasized that judicial review in such cases is limited to issues of jurisdiction or grave abuse of discretion, not a re-evaluation of the evidence. The existence of such a company policy legally entitled Melendres to the benefits, notwithstanding his voluntary resignation, to prevent unfair discrimination. The award was thus justified.