G.R. No. L-64190. January 31, 1985.
Polymedic General Hospital, petitioner, vs. Hon. National Labor Relations Commission and Ricardo Pasadilla, respondents.

FACTS

Polymedic General Hospital sought to terminate its janitor, Ricardo Pasadilla, on grounds of sleeping on duty and abandoning his post. The hospital filed a clearance application with the Ministry of Labor and placed Pasadilla under preventive suspension. Pasadilla opposed the application and filed a complaint for illegal dismissal. During the joint hearings, Pasadilla submitted his position paper and evidence, while the hospital failed to appear at a scheduled hearing and did not submit its position paper by the set deadline. The Labor Arbiter proceeded to hear Pasadilla’s evidence ex parte.
Pasadilla’s evidence revealed that on July 30, 1981, his salary was withheld, and he was told by a personnel officer, Alex Gonzales, that he was subject to termination. Gonzales instructed him to sign a pre-written resignation letter, promising he could continue working if he did so. After submitting the resignation, Pasadilla was instead informed he could no longer work. He retrieved and tore the resignation paper. Pasadilla denied all charges of negligence and misconduct, stating he had never been reprimanded or suspended before.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter’s decision that Pasadilla was illegally dismissed.

RULING

The Supreme Court dismissed the petition, upholding the NLRC’s decision. The legal logic centers on the burden of proof in termination cases. Under Article 280 of the Labor Code, the employer bears the burden to prove that a dismissal is for a just or authorized cause. Here, the hospital failed to discharge this burden. It did not submit its position paper or present evidence to substantiate its charges against Pasadilla during the proceedings before the Labor Arbiter, despite being given an opportunity. Its subsequent claim of having records of prior offenses was unsupported, as it did not present these records.
Conversely, Pasadilla presented substantial evidence supporting his claim of illegal dismissal, including the coercive attempt to secure a resignation and the lack of prior disciplinary action. The Court also noted the Labor Arbiter’s finding that the hospital’s clearance application appeared defective, as it lacked a file number from the Ministry of Labor. Since the employer failed to prove a valid cause for termination, the dismissal was unjust. The findings of fact by the Labor Arbiter and the NLRC, being consistent with the evidence, were accorded finality. However, the award of backwages was modified, granting Pasadilla only 50%.