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NATIONAL FEDERATION OF LABOR, Et Al., Petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION (5th Division), Et Al., Respondents. G.R. No. 127718 March 2, 2000

The petitioners were employees of a coconut estate that was acquired under the Comprehensive Agrarian Reform Law (CARL) in 1988, forcing the estate to shut down and severing the employment of the petitioners. The petitioners filed a complaint seeking reinstatement and back wages, claiming they were illegally dismissed. The Court dismissed the petition and ruled that the petitioners were not entitled to separation pay under Article 283 of the Labor Code, as that article only applies to closures and personnel reductions, not a situation where the closure was forced on the employer for the benefit of the employees as owners under CARL. The Court affirmed the ownership transfer to the petitioners under CARL superseded their claim to separation pay under

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84 views2 pages

NATIONAL FEDERATION OF LABOR, Et Al., Petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION (5th Division), Et Al., Respondents. G.R. No. 127718 March 2, 2000

The petitioners were employees of a coconut estate that was acquired under the Comprehensive Agrarian Reform Law (CARL) in 1988, forcing the estate to shut down and severing the employment of the petitioners. The petitioners filed a complaint seeking reinstatement and back wages, claiming they were illegally dismissed. The Court dismissed the petition and ruled that the petitioners were not entitled to separation pay under Article 283 of the Labor Code, as that article only applies to closures and personnel reductions, not a situation where the closure was forced on the employer for the benefit of the employees as owners under CARL. The Court affirmed the ownership transfer to the petitioners under CARL superseded their claim to separation pay under

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© © All Rights Reserved
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NATIONAL FEDERATION OF LABOR, et al., petitioners, vs.

NATIONAL LABOR RELATIONS


COMMISSION (5th Division), et al., respondents. G.R. No. 127718 March 2, 2000
FACTS: Petitioners are bona fide members of the National Federation of Labor (NFL), a
legitimate labor organization duly registered with the Department of Labor and Employment,
and were employed by private respondents Charlie Reith and Susie Galle Reith, general
manager, and owner, respectively. Patalon Coconut Estate was engaged in growing agricultural
products and in raising livestock. However, in 1988, Congress enacted into law Republic Act
(R.A.) No. 6657, otherwise known as the Comprehensive Agrarian Reform Law (CARL),
mandated the compulsory acquisition of all covered agricultural lands for distribution to
qualified farmer-beneficiaries under the so-called Comprehensive Agrarian Reform Programme
(CARP), thus, private respondents shut down and the employment of the petitioners was
severed. Petitioners did not receive any separation pay as they became part-owners of the
Patalon Coconut Estate pursuant to the CARP, thus, they filed a complaint praying for their
reinstatement with full back wages on the ground that they were illegally dismissed.
ISSUE/S: Whether or not petitioners are entitled to separation pay citing Article 283 of the
Labor Code.
RULING: No. The Court dismissed the petition and the resolutions of the NLRC were affirmed.
The Court highlighted that Article 283 of the Labor Code applies in cases of closures of
establishment and reduction of personnel. When the Patalon Coconut Estate was closed and
was acquired by DAR pursuant to CARP, the ownership of that large portion of the estate was
precisely transferred to PEARA and ultimately to the petitioners as members thereof and as
agrarian lot beneficiaries. Hence, the said code is not applicable to the case at the bench. It is a
rule in Statutory Construction, as a general rule, the intent of the legislature to be ascertained
and thereafter given effect is the intent expressed in the language of the statute. As
emphasized by the Court, the "plain meaning rule" or verba legis in statutory construction is
thus applicable in this case. Where the words of a statute are clear, plain, and free from
ambiguity, it must be given its literal meaning and applied without attempted interpretation.
In other words, Article 283 of the Labor Code does not contemplate a situation where the
closure of the business establishment is forced upon the employer and ultimately for the
benefit of the employees.

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