G.R. No.

200811

Facts of the Case: The case involves a group of Filipino overseas workers, including petitioners Julita M.
Aldovino and others, who were employed in Taiwan by Gold and Green Manpower Management and
Development Services, Inc. They faced illegal dismissal and unfavorable working conditions, including
being forced to sign contracts that altered their pay structure from a fixed monthly salary to a piece-rate
basis. After being dismissed, they filed a complaint in Taiwan but later entered into a Compromise
Agreement. Upon returning to the Philippines, they filed a case for illegal termination, underpayment of
salaries, and other claims against their employers. The Labor Arbiter initially ruled against them, but the
Court of Appeals reversed this decision, declaring the workers were illegally dismissed and entitled to
various monetary awards.

Issue: Whether or not the petitioners were entitled to their salaries for the unexpired portion of their
employment contracts, especially in light of the Compromise Agreement they had signed, which the
respondents argued barred further claims.

Ruling: The Supreme Court ruled in favor of the petitioners, stating that the Compromise Agreement did
not bar them from pursuing their claims for illegal dismissal. The Court declared that the clause reinstating
a three-month cap on salaries for illegally dismissed overseas workers, as stated in Republic Act No.
10022, was unconstitutional. Consequently, the petitioners were entitled to receive their salaries for the
unexpired portion of their contracts, along with reimbursement of their placement fees, moral and
exemplary damages, and attorney's fees. The ruling emphasized the protection of workers' rights under
Philippine law, regardless of the jurisdiction of their employment contracts.

G.R. No. 164774

Facts of the Case: The case involves Star Paper Corporation and its policy prohibiting spouses from
working in the same company. Employees Ronaldo D. Simbol, Wilfreda N. Comia, and Lorna E. Estrella
were compelled to resign due to this policy after they married co-workers. They later filed a complaint for
unfair labor practice and constructive dismissal, arguing that the policy violated their rights under the
Labor Code, specifically Article 136, which prohibits discrimination against women employees based on
their marital status. The Labor Arbiter initially dismissed their complaint, but the Court of Appeals reversed
this decision, declaring their dismissals illegal and ordering reinstatement.

Issue: Whether or not the company's policy banning spouses from working together constituted a valid
exercise of management prerogative or if it violated the employees' rights under the Labor Code and the
Constitution.

Ruling: The Supreme Court affirmed the Court of Appeals' decision, ruling that the policy was an invalid
exercise of management prerogative. The Court emphasized that the policy disproportionately affected
employees based on their marital status and lacked a reasonable business necessity to justify such
discrimination. The Court highlighted the importance of protecting labor rights and ruled that the
resignations of the employees were not voluntary, thus declaring their dismissals illegal. The decision
reinforced the principle that employment policies must not discriminate against employees based on their
marital status, aligning with the protections afforded under the Labor Code and the Constitution.

G. R. No. 221241

Facts of the Case: Mario N. Felicilda (petitioner) filed a complaint for illegal dismissal and money claims
against his former employer, Manchesteve H. Uy (respondent). Felicilda was hired as a truck driver for Uy’s
trucking service, "Gold Pillars Trucking." On December 9, 2011, while waiting for his truck to be loaded,
Felicilda took a nap at the work station. The following day, he was informed that his employment was
terminated due to this act. Felicilda claimed that he was dismissed without just cause and due process, as
his napping did not harm the business. The Labor Arbiter ruled in his favor, but the Court of Appeals later
dismissed the complaint for lack of merit, leading Felicilda to appeal to the Supreme Court.

Issue: Whether or not an employer-employee relationship existed between Felicilda and Uy, and
consequently, whether Felicilda was illegally dismissed.

Ruling: The Supreme Court ruled in favor of Felicilda, reversing the Court of Appeals' decision. The Court
found that an employer-employee relationship did exist, as all four elements of such a relationship were
present: (1) selection and engagement of the employee, (2) payment of wages (even on a commission
basis), (3) power of dismissal, and (4) control over the employee's conduct. The Court emphasized that the
right to control the means and methods of work is the most significant factor in determining this
relationship. Since Uy failed to provide just cause for the dismissal and did not follow due process,
Felicilda was deemed illegally dismissed and entitled to backwages and separation pay in lieu of
reinstatement. The decision of the National Labor Relations Commission was reinstated, affirming
Felicilda's rights as an employee.

GR No. 200555

Facts of the Case: Pedro Dusol and Maricel Dusol filed a complaint for illegal dismissal against Emmarck
Lazo, the owner of Ralco Beach, claiming they were employees. Emmarck contended that they were
industrial partners rather than employees. The Labor Arbiter dismissed the complaint due to a lack of
evidence establishing an employment relationship. However, the National Labor Relations Commission
(NLRC) ruled in favor of the Dusols, awarding them separation pay, damages, and attorney's fees. The
Court of Appeals reversed the NLRC's decision, asserting that the Dusols were not employees because
Emmarck did not exercise control over them. The Dusols appealed to the Supreme Court.

Issue: Whether or not Pedro and Maricel were employees of Emmarck or his industrial partners, and if
they were employees, whether their dismissal was valid.

Ruling: The Supreme Court ruled that Pedro and Maricel were indeed employees of Emmarck. The Court
found no evidence of a partnership, as Emmarck failed to substantiate his claims. The Court emphasized
that the control test is crucial in determining the existence of an employer-employee relationship. It
concluded that Emmarck had the power to control the Dusols' conduct, thus confirming their status as
employees. The Court reinstated the NLRC's decision, awarding the Dusols separation pay, nominal
damages, salary differentials, and 13th-month pay, while also noting that the closure of the business was
not due to serious losses, which entitled them to these benefits. The decision of the Court of Appeals was
reversed and set aside, and the NLRC's ruling was reinstated.

Digest of G.R. No. 169510

Facts of the Case: Jesus P. Gison was engaged by Atok Big Wedge Company, Inc. as a consultant on a
retainer basis for eleven years. His role involved assisting the company's legal counsel and performing
liaison work with government agencies. Gison requested registration with the Social Security System
(SSS), which was ignored by the company. Subsequently, his services were terminated, leading him to file
a complaint for illegal dismissal, claiming he was an employee entitled to benefits. The Labor Arbiter
dismissed his complaint, stating there was no employer-employee relationship. Gison appealed to the
National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's decision. Gison then
sought relief from the Court of Appeals, which ruled in his favor, ordering his reinstatement and payment
of backwages.

Issue: Whether or not an employer-employee relationship existed between Gison and Atok Big Wedge
Company, Inc., which would entitle Gison to the rights and benefits of a regular employee under Philippine
labor law.
Ruling: The Supreme Court reversed the Court of Appeals' decision, ruling that there was no
employer-employee relationship between Gison and Atok. The Court emphasized that Gison was hired as
a consultant with a clear understanding that his engagement was temporary and did not establish an
employment relationship. The Court applied the "control test," which showed that Atok did not control the
manner in which Gison performed his tasks. Consequently, the termination of Gison's services did not
constitute illegal dismissal, and he was not entitled to reinstatement or backwages. The petition was
granted, and the previous decisions of the NLRC were reinstated, affirming the absence of an
employer-employee relationship.

GR No. 233413

Facts of the Case: Noel Sacramento Saluta (respondent) filed a complaint against Celia R. Atienza
(petitioner) and CRV Corporation for illegal dismissal and other labor-related claims. Respondent alleged
he was hired as a driver by CRV Corporation in May 2012 with a monthly salary of Php 9,000. On
December 11, 2014, he had a vehicular accident and the damages were initially covered by the company
but were to be deducted from his salary. After failing to report to work on December 24, 2014, due to the
renewal of his driver’s license, he was told by the petitioner that their employment relationship should end.
Subsequently, the general manager of CRV Corporation also confirmed his termination. Respondent then
filed his complaint.Petitioner contended that respondent was her personal driver and abandoned his job
without permission. The Labor Arbiter ruled in favor of the petitioner, stating he was a personal driver not
covered by the Labor Code but the Civil Code. On appeal, the NLRC reversed this, ruling that respondent
was a company driver and declared he was illegally dismissed. The Court of Appeals affirmed the NLRC’s
decision but mandated petitioner and CRV Corporation to pay respondent his monetary claims.

Issues:
1. Whether or not the respondent was a company driver employed by CRV Corporation or a personal
driver hired by petitioner.
2. Whether or not the respondent was illegally dismissed from his employment or abandoned his job.
3. Whether or not the respondent is entitled to full backwages, separation pay, wage differentials, holiday
pay, 13th month pay, and service incentive leave pay.

Ruling:
1. The Supreme Court ruled that respondent did not establish by substantial evidence that he was a
company driver for CRV Corporation. No competent evidence such as an employment contract, company
ID, or payroll inclusion was presented. Therefore, the Court upheld the Labor Arbiter’s finding that
respondent was the personal/family driver of petitioner.
2. The Court found that respondent failed to present substantial evidence that he was dismissed by the
petitioner. His claim of verbal termination was not corroborated by any other evidence. The refusal to
release his salary was not sufficient proof of dismissal.
3. The Court ruled that respondent did not abandon his work. No clear intention from the respondent to
sever the employer-employee relationship was proven. His filing of the illegal dismissal case itself was
incompatible with abandonment of employment. Since the respondent was considered a personal/family
driver, his rights were governed by the Civil Code, not the Labor Code. The monthly salary of Php 9,000
was reasonable. As a personal driver, he was not entitled to holiday pay, 13th month pay, or service
incentive leave pay.

Digest of G.R. No. 227734

Facts of the Case: Romeo Alba, the petitioner, faced complaints from construction workers who alleged
illegal dismissal and non-payment of statutory benefits. The workers claimed they were regular employees
of Alba Construction, hired for various projects, and were entitled to benefits such as overtime pay, 13th
month pay, and service incentive leave. Initially, the Labor Arbiter dismissed the complaints, stating no
employer-employee relationship existed. However, the National Labor Relations Commission (NLRC)
partially granted the workers' appeal, ruling that they were indeed regular employees entitled to
reinstatement and backwages. The Court of Appeals affirmed the NLRC's decision, leading Alba to file a
Petition for Review on Certiorari.

Issue: Whether or not an employer-employee relationship existed between Alba and the workers, and if
the dismissal was legal or constituted illegal dismissal.

Ruling: The Supreme Court affirmed the decisions of the lower courts, concluding that the workers were
regular employees of Alba. The Court applied the four-fold test to establish the employer-employee
relationship, which included the selection and engagement of employees, payment of wages, power of
dismissal, and control over the employees' conduct. The Court found that Alba exercised significant
control over the workers, thus confirming their status as regular employees. Consequently, Alba was held
liable for illegal dismissal and ordered to pay the workers backwages, moral and exemplary damages, and
attorney's fees, totaling P16,125,574.61. The ruling emphasized that the dismissal was retaliatory, occurring
after the workers sought their rightful benefits.

Digest of G.R. No. 223825

Facts of the Case: Luis G. Gemudiano, Jr. applied for employment as a seaman with Naess Shipping
Philippines, Inc. and underwent a pre-employment medical examination (PEME), where he was declared fit
for sea service. He signed a contract of employment that was to take effect on March 12, 2013. However,
shortly before his deployment, Naess Shipping informed him that his embarkation was canceled due to a
pre-existing medical condition (diabetes and asthma) that he allegedly failed to disclose. Gemudiano filed
a complaint for breach of contract with the Labor Arbiter, who ruled in his favor, ordering the respondents
to pay damages. The Court of Appeals later annulled this decision, stating there was no
employer-employee relationship, thus the Labor Arbiter lacked jurisdiction.

Issue: Whether or not the Labor Arbiter had jurisdiction over Gemudiano's complaint for breach of
contract, given the Court of Appeals' ruling that there was no employer-employee relationship due to the
non-commencement of the contract.

Ruling: The Supreme Court reversed the Court of Appeals' decision, reinstating the Labor Arbiter's ruling.
It held that a perfected contract of employment existed between Gemudiano and the respondents,
establishing an employer-employee relationship. The Court emphasized that the cancellation of his
deployment did not negate the obligations arising from the contract, and thus, the Labor Arbiter had
jurisdiction over the case. The Court ruled that the stipulation in the contract regarding the
commencement of employment was a potestative condition, which is void, thereby affirming the Labor
Arbiter's authority to hear the case and award damages to Gemudiano for breach of contract.

Case Digest: Abadilla vs. PAGCOR (G.R. No. 258658)

Facts of the Case: Mark Abadilla, et al. were hired by the Philippine Amusement and Gaming Corporation
(PAGCOR) for various positions in its hotel and restaurant business. Their employment was documented
through fixed-term contracts, which were sometimes renewed. Their total length of service with PAGCOR
ranged from one to seventeen years. The petitioners were compensated on a "no work, no pay" basis and
performed tasks considered necessary and desirable to PAGCOR's operations. They claimed they were
deprived of benefits typically given to regular PAGCOR employees. PAGCOR decided to close its hotel
business in one location and transfer to another, also deciding not to renew the petitioners’ contracts. This
led to the filing of a complaint for illegal dismissal. The case went through several procedural stages,
including actions before the Civil Service Commission (CSC) and the Regional Trial Court.

Issue: Whether or not Abadilla, et al., were regular employees of PAGCOR, and thus covered by civil
service laws, or contract of service/job order workers.
Ruling: The Supreme Court ruled that the petitioners were contract of service and job order workers. The
Court held that PAGCOR has the authority to hire its own employees, as well as contract of service or job
order workers. The determination of an employer-employee relationship in the public sector is governed by
specific laws, civil service laws, and their corresponding rules and regulations. The Court found that the
petitioners were not regular employees under the civil service, and therefore, the Civil Service Commission
did not have jurisdiction over their case. The Supreme Court emphasized that not all personnel hired by
PAGCOR are considered government employees under the Civil Service. Some are hired under contracts of
service or job orders and are not covered by the CSC.

Digest of G.R. No. 85985

Facts of the Case: The case involves Philippine Airlines, Inc. (PAL) and the National Labor Relations
Commission (NLRC), along with the Philippine Airlines Employees Association (PALEA). In 1985, PAL
revised its Code of Discipline, which led to complaints from PALEA regarding unfair labor practices. PALEA
argued that PAL implemented the new Code without prior discussion with the union, which they claimed
violated their rights. The labor arbiter found PAL at fault for the arbitrary implementation of the Code and
ordered PAL to furnish all employees with a new Code of Discipline. The NLRC affirmed the dismissal of
the unfair labor practice charge but directed PAL to review and discuss the disputed provisions with the
union. PAL subsequently filed a petition for certiorari.

Issue: Whether or not the formulation of a Code of Discipline among employees is a shared responsibility
between the employer and the employees, and whether PAL could be compelled to share its management
prerogative in this regard.

Ruling: The Supreme Court dismissed PAL's petition, affirming the NLRC's decision. The Court emphasized
that while management has the prerogative to formulate rules, this prerogative is not absolute and must
be exercised with transparency and fairness. The Court highlighted the importance of employee
participation in discussions that affect their rights, particularly in matters concerning discipline, which can
impact job security. The ruling underscored the need for a cooperative relationship between management
and labor, recognizing that employees have a right to be involved in decisions that affect their
employment conditions.

Digest of G.R. No. 212054 (2015)

Facts of the Case: Maria Theresa V. Sanchez was employed as a staff nurse at St. Luke's Medical Center,
Inc. (SLMC). On May 29, 2011, she was found attempting to take medical supplies out of the hospital,
which violated SLMC's Code of Discipline. Following an investigation, SLMC terminated her employment
for "acts of dishonesty." Sanchez claimed she inadvertently left the supplies in her bag and argued that
her actions were not intended for personal gain. The Labor Arbiter ruled her dismissal valid, but the
National Labor Relations Commission (NLRC) later reversed this decision, declaring her dismissal illegal.
The Court of Appeals upheld the NLRC's ruling.

Issue: Whether or not Sanchez was illegally dismissed by SLMC for her actions regarding the medical
supplies.

Ruling: The Supreme Court ruled that Sanchez's dismissal was valid and for just cause. The Court
emphasized that her actions constituted a willful disregard of SLMC's rules, which were reasonable and
known to her. The Court found that her admission of wrongdoing in a handwritten letter indicated her
awareness of the violation. The ruling of the NLRC was deemed erroneous, and the Supreme Court
reinstated the Labor Arbiter's decision, affirming that SLMC had just cause for termination due to
Sanchez's acts of dishonesty, which were connected to her employment duties.
Digest of G.R. No. 215314

Facts of the Case: The case involves the dismissal of Zuelo Apostol, an employee of Central Azucarera de
Bais (CAB), for violating company rules by using company equipment and materials to repair his personal
vehicles without permission. The violation was discovered during an inspection, leading to a memorandum
from CAB management requiring Apostol to explain his actions. He admitted to the violation in his
response. Following this, CAB terminated his employment, citing the violation of company rules. Apostol
filed a complaint for constructive dismissal, which was initially dismissed by the Labor Arbiter but later
reversed by the National Labor Relations Commission (NLRC) and the Court of Appeals (CA). The CA
upheld the NLRC's decision, stating that while Apostol violated company rules, the penalty of dismissal
was too severe.

Issue: Whether or not CAB complied with procedural and substantive due process in terminating Apostol's
employment and whether the penalty of dismissal was commensurate with the violation committed.

Ruling: The Supreme Court reversed the decisions of the CA and NLRC, ruling that CAB had complied with
both procedural and substantive due process in terminating Apostol's employment. The Court emphasized
that the employer has the right to exercise management prerogative, including the right to dismiss
employees for just cause. The Court found that Apostol's actions warranted dismissal due to the violation
of trust and company rules, and thus he was not entitled to backwages or separation pay. The ruling
reinforced the principle that employers can impose penalties commensurate with the gravity of the
employee's misconduct, particularly when the employee holds a position of trust and responsibility.

Digest of G.R. No. 172724

Facts of the Case: The case involves Ricardo Albayda, Jr., an employee of Pharmacia and Upjohn, Inc.
(now Pfizer Philippines, Inc.), who was reassigned from District XI in the Western Visayas area to District
XII in Northern Mindanao. Albayda objected to this reassignment, claiming it was unreasonable and
would lead to his dismissal. After a series of communications with the company regarding his transfer, he
was placed on indefinite sick leave and subsequently failed to report for work. The company eventually
terminated his employment, citing absence without official leave (AWOL) and insubordination.
Albayda filed a complaint for constructive dismissal with the National Labor Relations Commission
(NLRC), which was initially dismissed by the Labor Arbiter. The NLRC affirmed this dismissal, but the Court
of Appeals later ruled in favor of Albayda, finding the reassignment unreasonable and the dismissal void
due to lack of due process.

Issue: Whether or not the Court of Appeals erred in reversing the factual and legal findings of the NLRC,
which upheld the dismissal of Albayda based on substantial evidence.

Ruling: The Supreme Court reversed the decision of the Court of Appeals, reinstating the findings of the
Labor Arbiter and the NLRC. The Court held that the reassignment was a valid exercise of management
prerogative and that Albayda's dismissal was justified due to his refusal to comply with the lawful order of
transfer. The Court emphasized that the employer's decision to transfer employees is generally respected
unless proven to be arbitrary or unreasonable. The Court also ruled that Albayda was entitled to
separation pay as a form of financial assistance, given his long years of service, despite the valid grounds
for his dismissal.

Digest of G.R. No. 189366

Facts of the Case: Eusebio Honrado was employed by the Philippine Long Distance Telephone Company
(PLDT) as a senior lineman. He was accused of soliciting and receiving a downpayment of P1,500.00 from
spouses Pete and Rodrigo Mueda for the installation of a telephone line, which was against company
policy. Following an investigation, Honrado was dismissed from service. The National Labor Relations
Commission (NLRC) initially ruled in favor of Honrado, ordering his reinstatement and payment of back
wages. However, the Court of Appeals affirmed the NLRC's decision. PLDT then appealed to the Supreme
Court.

Issue: Whether or not Honrado was afforded due process during the dismissal proceedings and whether
there was just cause for his termination.

Ruling: The Supreme Court ruled in favor of PLDT, reversing the decisions of the NLRC and the Court of
Appeals. The Court found that Honrado was given a fair opportunity to defend himself during the
investigation and that the dismissal was justified based on substantial evidence of misconduct. The Court
emphasized that due process does not always require a formal hearing, and the employer's right to
enforce discipline must also be respected. The ruling reinstated the Labor Arbiter's decision dismissing
Honrado's complaint for lack of merit.

Digest of G.R. No. 75662

Facts of the Case: Cesar Ladisla was employed as a Stock Analyst by Mercury Drug Corporation. He was
apprehended for pilfering company property, specifically three bottles of Persantin and one bottle of
Valoron, valued at P272.00. Ladisla admitted his guilt during the investigation and was subsequently
charged with theft. The company filed for his termination based on dishonesty and breach of trust. The
Labor Arbiter initially upheld the termination, but the National Labor Relations Commission (NLRC) later
reversed this decision, ordering his reinstatement with full back wages. The NLRC found insufficient
evidence to justify the termination.

Issue: Whether or not the NLRC erred in reversing the Labor Arbiter's decision and ordering the
reinstatement of Ladisla despite his admission of guilt and subsequent conviction for theft.

Ruling: The Supreme Court ruled in favor of Mercury Drug Corporation, reversing the NLRC's decision. The
Court held that the NLRC committed a grave abuse of discretion by disregarding the conviction of Ladisla
for theft, which provided substantial evidence for his dismissal. The Court emphasized that an employer
has the right to terminate an employee for acts that undermine trust, and that the law does not require
proof beyond a reasonable doubt for dismissal based on loss of confidence. The Court reinstated the
Labor Arbiter's decision to terminate Ladisla's employment, affirming the company's right to protect its
interests against dishonest employees.

Digest of G.R. No. 126703

Facts of the Case: The case involves a petition filed by Gandara Mill Supply and its owner, Milagros Sy,
against the National Labor Relations Commission (NLRC) and Silvestre Germano. The private respondent,
Germano, was dismissed from his job, which he claimed was illegal. He had been absent from work
without notifying his employer due to personal reasons related to his wife's childbirth. After his absence,
he was informed that someone else had been hired to take his place. Germano filed a case for illegal
dismissal with the Department of Labor and Employment (DOLE). The Labor Arbiter ruled in favor of
Germano, ordering Gandara Mill Supply to pay him P65,685.90 for separation pay, backwages, and
attorney’s fees. The petitioners appealed the decision to the NLRC, which dismissed their appeal for
failure to post a cash or surety bond.

Issue: Whether or not the NLRC acted with grave abuse of discretion in dismissing the petitioners' appeal
and in awarding Germano the amount of P65,685.90, which the petitioners claimed was excessive.

Ruling: The Supreme Court affirmed the NLRC's decision, ruling that the petitioners failed to prove their
claims. The Court held that the petitioners were given ample opportunity to present their case but failed to
comply with procedural requirements, thus waiving their right to be heard. The Court also found that the
amount awarded to Germano was not excessive given the circumstances of the case. The petition was
dismissed on the grounds that it was filed out of time and devoid of merit, with the NLRC's resolution
upheld in its entirety.

Digest for GR No. 188747

Facts of the Case: Carlito Del Rosario was an employee of Manila Water Company, originally from MWSS,
who was absorbed by Manila Water during a reorganization. In May 2000, Manila Water discovered 24
water meters were missing from its stockroom. Upon investigation, Del Rosario and a co-employee were
found involved in pilfering and selling water meters to a company contractor. Manila Water issued a
memorandum directing Del Rosario to explain the incident. In his response, Del Rosario confessed his
involvement and pleaded for forgiveness.

Issue: Whether or not Del Rosario is entitled to separation pay after being dismissed for serious
misconduct involving theft of company property.

Ruling: The Supreme Court ruled that Del Rosario is NOT entitled to separation pay because his dismissal
was for serious misconduct that reflects on his moral character. Granting separation pay would effectively
reward wrongdoing, which goes against the principles of social justice. The Court emphasized that social
justice is not meant to protect workers who have proven themselves unworthy of protection. Even though
Del Rosario had 21 years of service, this did not entitle him to separation pay, as rewarding long-serving
employees who commit serious misconduct would encourage further wrongdoing. The Supreme Court
reversed the Court of Appeals' decision and denied separation pay to Del Rosario.

Digest of G.R. No. 83320

Facts of the Case: The case involves the Philippine National Construction Corporation (PNCC) and
Domingo Manreza, who was employed as a janitor and later promoted to Leadsman. Manreza was found
to have stolen company property, specifically flexbeams, which were discovered in the homes of two
individuals. Following an investigation, PNCC dismissed Manreza for serious misconduct. He subsequently
filed a complaint for illegal dismissal and unfair labor practice, seeking back wages and damages. The
Labor Arbiter ruled in favor of Manreza, ordering his reinstatement without back wages. However, the
National Labor Relations Commission (NLRC) upheld the dismissal but awarded him separation pay as a
measure of social justice.

Issue: Whether or not an employee dismissed for serious misconduct, such as theft, is entitled to
separation pay despite the finding of a valid dismissal.

Ruling: The Supreme Court granted PNCC's petition, ruling that employees dismissed for serious
misconduct or offenses reflecting on their moral character are not entitled to separation pay. The Court
emphasized that the policy of social justice does not condone wrongdoing and that separation pay should
only be awarded in cases where the dismissal is valid but not for serious misconduct. Consequently, the
NLRC's award of separation pay to Manreza was deleted, affirming that he was not entitled to such
compensation due to the nature of his dismissal.

Digest of G.R. No. 184397

Facts of the Case: The case involves Rosalinda G. Paredes, who was the National Director of Feed the
Children Philippines, Inc. (FTCP). Paredes alleged that she was constructively dismissed from her position.
The labor tribunals initially ruled in her favor, but the Court of Appeals (CA) reversed this decision, stating
that she voluntarily resigned. Paredes claimed that the working environment became intolerable due to
the actions of the Board of Trustees, which included exclusion from meetings and a surprise audit. She
filed a complaint for illegal dismissal after submitting her resignation letter, which was accepted by the
Board.
Issue: Whether or not Paredes was constructively dismissed or if she voluntarily resigned from her
position at FTCP.

Ruling: The Supreme Court partly granted Paredes' petition, affirming the CA's ruling that she was not
constructively dismissed. The Court emphasized that Paredes failed to provide clear and positive evidence
to support her claim of constructive dismissal. The awards for unpaid debt and reimbursement from the
FTCP provident fund were set aside, as they lacked a reasonable causal connection to the
employer-employee relationship. The Court reiterated that mere allegations of constructive dismissal,
without substantial evidence, cannot be given credence.

Digest of G.R. No. 160123

Facts of the Case: Aguinaldo Naluis was employed by Centro Project Manpower Services Corporation to
work abroad as a plumber under Pacific Micronesia Corporation in the Commonwealth of the Northern
Mariana Islands. His employment contract was for 12 months, commencing upon his arrival. However, he
was repatriated before completing this period, which led him to file a complaint for illegal dismissal. The
Labor Arbiter initially ruled in favor of Centro Project, stating that his repatriation was justified due to the
expiration of his employment contract as per the Authorization for Entry (AE) issued by the Department of
Labor and Immigration of Northern Mariana Islands. This decision was upheld by the National Labor
Relations Commission (NLRC). Naluis appealed to the Court of Appeals, which reversed the previous
decisions, ruling that the AE did not limit his stay and that his repatriation constituted a breach of
contract.

Issue: Whether or not the expiration date contained in the AE validly cut short Naluis’ stay and justified
the pre-termination of his employment.

Ruling: The Supreme Court affirmed the Court of Appeals' decision, stating that Centro Project failed to
prove that the AE limited Naluis' stay. The Court emphasized that doubts in employment contracts should
be resolved in favor of the worker. It ruled that Naluis' repatriation was unjustified, and thus, he was
entitled to various monetary claims, including unpaid salaries and vacation leave pay, but not guaranteed
overtime pay and legal holiday pay. The Court ordered Centro Project to pay Naluis the amounts specified
in the appellate court's decision, except for the aforementioned claims.

Case Digest: Abella/Danao-Ramona vs. NLRC (G.R. No. 71813)

Facts of the Case: Rosalina Perez Abella was the lessee of a farmland known as Hacienda
Danao-Ramona. She initially leased the land for ten years and then extended the lease for another ten
years. During her leasehold, Abella employed Ricardo Dionele, Sr., and Romeo Quitco. Dionele had worked
on the farm for 33 years, and Quitco for 14 years. Upon the expiration of her leasehold rights, Abella
terminated the employment of Dionele and Quitco. She then turned over the hacienda to its owners, who
continued to manage and operate the farm. Dionele and Quitco filed a complaint against Abella with the
Ministry of Labor and Employment, seeking overtime pay, claiming illegal dismissal, and demanding
reinstatement with back wages. The Labor Arbiter ruled that the dismissal of the employees was justified
due to the cessation of business. However, the Labor Arbiter granted the employees separation pay. The
National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. Abella then appealed
the NLRC's decision to the Supreme Court.

Issue: Whether or not the employees, Ricardo Dionele, Sr., and Romeo Quitco, are entitled to separation
pay due to the termination of their employment following the expiration of the employer's leasehold.

Ruling: The Supreme Court upheld the decision to grant separation pay to the employees. The Court
applied Article 284 of the Labor Code, as amended by Batas Pambansa Blg. 130. This provision protects
workers whose employment is terminated due to the closure of an establishment or a reduction in
personnel. The Supreme Court emphasized the importance of protecting workers' welfare in the
interpretation and implementation of the Labor Code. Even though the employees were absorbed by the
new management of the hacienda, the Court ruled that, absent any showing that the new management
assumed the responsibilities of the former employer, the employees' prior years of service under the
former employer should be recognized through separation pay.

Case Digest: People vs. Manalang (G.R. No. 198015)

Facts of the Case: Avelina Manalang was charged with Illegal Recruitment in Large Scale under Republic
Act No. 8042 (RA 8042), also known as the Migrant Workers and Overseas Filipinos Act of 1995, and three
counts of Estafa under Article 315(2)(a) of the Revised Penal Code (RPC). Manalang misrepresented
herself as having the capacity to recruit workers for overseas employment. She collected placement fees
from complainants but failed to deploy them for work abroad. The illegal recruitment activities occurred
between June 2000 and May 28, 2001. The complainants, Ma. Teresa P. Marañon, Lolita V. Tura, and
Edgardo R. Cawas were defrauded by Manalang, who made false promises of overseas employment and
obtained money from them. Manalang collected PhP 80,000.00 from Marañon, PhP 56,000.00 from Tura,
and PhP 65,000.00 from Cawas. The Regional Trial Court (RTC) found Manalang guilty beyond reasonable
doubt of Illegal Recruitment in Large Scale and three counts of Estafa. The Court of Appeals (CA) affirmed
the RTC's decision.

Issue: Whether or not the Court of Appeals correctly upheld the conviction of Manalang for Illegal
Recruitment in Large Scale under RA 8042 and three counts of Estafa under Article 315(2)(a) of the RPC.

Ruling: The Supreme Court affirmed the conviction of Manalang for Illegal Recruitment in Large Scale
and three counts of Estafa. The Court held that Manalang engaged in recruitment activities without the
necessary license or authority from the Department of Labor and Employment (DOLE). The Court also
found that Manalang committed Estafa by defrauding the complainants through false pretenses and
fraudulent acts, which induced them to part with their money. The Supreme Court modified the penalties
imposed by the lower courts, particularly increasing the fine for Illegal Recruitment and adjusting the
sentences for the Estafa convictions in accordance with Republic Act No. 10951.

Digest of G.R. No. 199497

Facts of the Case: Delia Camannong was accused of large-scale illegal recruitment for promising
overseas employment to several individuals without the necessary license or authority. The complainants,
including Joel G. Salva, Marvin Albano, Reynaldo Salva, Jr., Rolly Calixtro, and Roger Cabael, testified that
they were recruited by Camannong, who misrepresented her ability to send them abroad. They paid her
various amounts totaling P6,500.00 each for processing fees, believing they would be deployed to Israel.
However, none of them were able to leave as promised. The absence of receipts for these payments was
noted, but the complainants maintained that they had indeed paid Camannong. The Regional Trial Court
(RTC) found her guilty, and the Court of Appeals (CA) affirmed the conviction, increasing the fine imposed.

Issue: Whether or not the CA correctly affirmed Camannong's conviction for illegal recruitment on a large
scale and properly imposed the penalty provided by law.

Ruling: The Supreme Court upheld the decision of the CA, affirming Camannong's conviction. The Court
ruled that the essential elements of illegal recruitment were established: Camannong engaged in
recruitment without the required authority and committed unlawful acts against three or more persons.
The lack of receipts did not hinder the complainants' right to recover damages, as their testimonies were
sufficient to prove the payments made to Camannong. The Court emphasized that the absence of
receipts should not prevent victims of fraud from seeking justice. Camannong was sentenced to life
imprisonment and ordered to pay actual damages of P6,500.00 to each complainant, with legal interest
from the time of filing the information until fully paid.
Digest of G.R. No. 93666

Facts of the Case: The case involves General Milling Corporation and Earl Timothy Cone, who petitioned
for the reversal of the Secretary of Labor's decision to cancel Cone's alien employment permit. Cone, a
United States citizen, was initially granted an alien employment permit to work as a sports consultant and
assistant coach for General Milling Corporation. However, the permit was later revoked by the Secretary of
Labor on the grounds that there was no evidence showing that there were no qualified local applicants for
the position and that Cone's employment would not serve the national interest. The petitioners filed a
Motion for Reconsideration, which was denied, prompting them to seek relief from the Supreme Court.

Issue: Whether or not the Secretary of Labor abused his discretion in revoking Cone's alien employment
permit and whether the requirement for an alien employment permit was consistent with the Labor Code.

Ruling: The Supreme Court dismissed the petition for lack of merit, affirming that the Secretary of Labor
did not abuse his discretion. The Court held that the requirement for an alien employment permit is in line
with the Labor Code, which mandates that employers must demonstrate the non-availability of local
workers before hiring foreign nationals. The Court emphasized that the Secretary of Labor has the
authority to determine the necessity of employing an alien based on the national interest and the
availability of local talent. The decision underscored the legal framework governing the employment of
aliens in the Philippines, reinforcing the statutory requirements that must be met by employers seeking to
hire foreign workers.

Digest of G.R. No. 204684

Facts of the Case: Allan Regala filed a complaint for constructive dismissal and regularization against
Manila Hotel Corporation (MHC). The National Labor Relations Commission (NLRC) initially declared
Regala a regular employee who was constructively dismissed. However, the Court of Appeals (CA) later set
aside this decision, asserting that Regala was a fixed-term employee. Regala argued that MHC reduced
his workdays from five to two, leading to a significant decrease in his salary, which he claimed amounted
to constructive dismissal.

Issue: Whether or not Regala was a regular employee of MHC and whether he was constructively
dismissed from his employment.

Ruling: The Supreme Court ruled in favor of Regala, reinstating the NLRC's decision that he was a regular
employee and had been constructively dismissed. The Court found that the fixed-term contracts
presented by MHC were invalid and did not meet the criteria for valid fixed-term employment. The
reduction of Regala's workdays constituted constructive dismissal, and the Court ordered his
reinstatement and the computation of his backwages from the date of his constructive dismissal. The
case was remanded to the Labor Arbiter for the re-computation of Regala's full backwages.

Digest of G.R. No. L-48494 (Brent School, Inc. v. Zamora)

Facts of the Case: The case revolves around the employment contract between Brent School, Inc. and
Doroteo Alegre, who was hired as an athletic director for a fixed term of five years. As the contract neared
its expiration on July 17, 1976, Brent School notified Alegre of the termination of his services due to the
completion of the contract. Alegre contested this termination, arguing that he had acquired the status of a
regular employee and could not be dismissed without just cause. Various labor authorities initially ruled in
favor of Alegre, asserting that his termination was unlawful. However, Brent School appealed these
decisions.

Issue: Whether or not the termination of Alegre's employment at the end of the fixed term was lawful,
considering Alegre's claim that he had become a regular employee entitled to protection against dismissal
without just cause.
Ruling: The Supreme Court ruled in favor of Brent School, declaring that the termination of Alegre's
employment was lawful due to the expiration of the agreed term of the contract. The Court emphasized
the validity of fixed-term employment contracts and upheld the freedom of the parties to determine the
duration of their engagement. It clarified that the expiration of a fixed-term contract constitutes a lawful
ground for termination, and Alegre was not entitled to reinstatement or any other relief. The decision
reversed the earlier rulings of labor authorities that favored Alegre's claim of regular employment status.

Case Digest: Labajo vs. Alejandro (G.R. No. L-80383)

Facts of the Case: Six teachers entered into fixed-term employment contracts with San Andres High
School. Upon the expiration of these contracts, the school did not renew them, leading the teachers to
allege illegal dismissal. The school countered that the teachers were probationary employees, subject to a
three-year probationary period to attain permanent status, as per the Manual of Regulations for Private
Schools. The school argued that the non-renewal of the fixed-term contracts did not equate to illegal
dismissal. The Labor Arbiter ruled in favor of the teachers, ordering reinstatement, backwages, and
payment of benefits, predicated on the teachers' right to security of tenure. The National Labor Relations
Commission (NLRC) affirmed the Labor Arbiter's decision.

Issues:
1.​ Whether or not the non-renewal of fixed-term contracts constituted illegal dismissal.
2.​ Whether or not the teachers were correctly classified as probationary employees.
3.​ Whether or not the expiration of a fixed-term contract is a valid ground for termination of
employment.
4.​ Whether or not the extent of security of tenure afforded to probationary employees, particularly
in the context of fixed-term contracts.

Ruling:
1.​ The Supreme Court held that the non-renewal of the fixed-term contracts did not constitute illegal
dismissal.
2.​ The teachers were deemed probationary employees, as they had not yet achieved the requisite
three years of service for permanent status.
3.​ The Court affirmed that the expiration of a fixed-term contract is a valid cause for the
termination of employment.
4.​ The Court clarified that probationary employees enjoy security of tenure only for the duration of
their contractual term. The expiration of the contract extinguishes this security, and the employer
is not obligated to renew the contract. The school was, however, held liable for the payment of
unpaid benefits.

Case Digest: Carpio vs. Modair Manila Co. Ltd., Inc. (G.R. No. 239622)

Facts of the Case: Ruben Carpio was employed by Modair Manila Co. Ltd., Inc. (Modair) from 1998 to
2013, primarily as an electrician. Carpio's employment history involved being repeatedly rehired for various
construction projects. Modair classified him as a "contractor's employee (per project basis)." Carpio filed a
complaint for illegal dismissal and regularization, arguing that his continuous rehiring made him a regular
employee and that he was illegally dismissed after a project ended. Modair argued that Carpio was a
project-based employee, and his employment lawfully ended with each project's completion.

Issues:
1.​ Whether or not Carpio was a regular or project-based employee of Modair.
2.​ Whether or not Carpio was illegally dismissed.
Ruling:
1.​ The Supreme Court ruled that Carpio was a regular employee of Modair. The Court considered the
following factors: the continuous rehiring of Carpio for various projects, and the fact that Carpio's
work as an electrician was vital and necessary to Modair's construction business.
2.​ The Supreme Court found that Carpio was not illegally dismissed. The Court reasoned that
Carpio's employment was terminated due to the completion of the specific project he was
assigned to.

Digest of G.R. No. 152427

Facts of the Case: The case involves a petition for review filed by Integrated Contractor and Plumbing
Works, Inc. against the National Labor Relations Commission (NLRC) and Glen Solon. The NLRC had
previously ruled that Glen Solon was a regular employee of the petitioner and awarded him benefits
including 13th month pay, service incentive leave pay, and full backwages. The petitioner contended that
Solon was a project employee, arguing that his employment was tied to specific projects and thus did not
warrant the benefits awarded.

Issue: Whether or not Glen Solon was a regular employee entitled to benefits under the Labor Code or a
project employee whose employment was contingent upon the completion of specific projects.

Ruling: The Supreme Court affirmed the decision of the NLRC, ruling that Glen Solon was indeed a regular
employee. The Court found that the nature and duration of Solon's work indicated that he was engaged in
activities that were necessary and desirable to the usual business of the petitioner. Consequently, the
Court ordered the petitioner to reinstate Solon with no loss of seniority rights and to pay him backwages,
13th month pay for the year 1998, and service incentive leave pay. The ruling emphasized that the
repeated hiring of Solon for essential tasks established his status as a regular employee, thus entitling him
to security of tenure and the associated benefits under the Labor Code.

Digest of G.R. No. 198587

Facts of the Case: The case involves a Petition for Review on Certiorari filed by Saudi Arabian Airlines
(Saudia) and Brenda J. Betia against the decision of the Court of Appeals, which held them liable for the
illegal dismissal and underpayment of salary and benefits of flight attendants Ma. Jopette M. Rebesencio,
Montassah B. Sacar-Adiong, Rouen Ruth A. Cristobal, and Loraine S. Schneider-Cruz. The respondents
were terminated while pregnant, despite having approved maternity leaves. Saudia argued that the
termination was based on its "Unified Employment Contract for Female Cabin Attendants," which
rendered the employment void upon pregnancy. The respondents contended that their termination was
illegal and sought relief for back wages, separation pay, and damages.

Issue: Whether or not the Labor Arbiter and the National Labor Relations Commission (NLRC) had
jurisdiction over Saudia and whether the respondents voluntarily resigned or were illegally terminated.

Ruling: The Supreme Court ruled that the Labor Arbiter and the NLRC had jurisdiction over Saudia,
affirming that it was a foreign corporation doing business in the Philippines and could be sued in
Philippine courts. The Court found that the respondents were constructively dismissed, as they were
compelled to resign under threat of termination due to their pregnancies. The Court ruled that their
termination was illegal, entitling them to full back wages, separation pay, moral and exemplary damages,
and attorney's fees. The Court also clarified that Brenda J. Betia could not be held personally liable for the
illegal termination. The decision of the Court of Appeals was modified to reflect these findings, and the
case was remanded to the Labor Arbiter for computation of the amounts due to the respondents.
Digest of G.R. No. 195297

Facts of the Case: The case involves Coca-Cola Bottlers Philippines, Inc. (CCBPI) and the Iloilo Coca-Cola
Plant Employees Labor Union (ICCPELU). The dispute arose when CCBPI decided to discontinue Saturday
work, which had been a part of the employees' work schedule. The employees, represented by the union,
claimed that this decision violated their Collective Bargaining Agreement (CBA), which stipulated that
Saturday work was part of their normal work week. The union argued that the removal of Saturday work
constituted a prohibited diminution of benefits. The National Conciliation and Mediation Board (NCMB)
initially ruled in favor of the union, but the Court of Appeals reversed this decision, leading CCBPI to
appeal to the Supreme Court.

Issue: Whether or not the Court of Appeals erred in ruling that the CBA mandated CCBPI to schedule
Saturday work for its employees and whether the discontinuation of Saturday work constituted a
prohibited diminution of benefits.

Ruling: The Supreme Court reversed the decision of the Court of Appeals, ruling that the CBA clearly
provided CCBPI with the option to schedule work on Saturdays based on operational necessity. The Court
emphasized that the scheduling of Saturday work was not mandatory and that the removal of Saturday
work did not violate the non-diminution of benefits rule. The Court upheld the principle of "no work, no
pay," affirming that employees were not entitled to wages for unworked Saturdays. The decision of the
NCMB was reinstated, affirming CCBPI's management prerogative to determine work schedules based on
operational needs.

Digest of G.R. No. 224944

Facts of the Case: Reggie Orbista Zonio, a security guard, filed a complaint against 1st Quantum Leap
Security Agency, Inc. and its owner, Romulo Q. Par, for illegal suspension, underpayment of salary, and
non-payment of various benefits. Zonio claimed he was suspended without a formal investigation for
allegedly sleeping on duty. He also asserted that he was not compensated for overtime work, holiday pay,
and other benefits. The Labor Arbiter initially ruled that Zonio was validly suspended but entitled to some
salary differentials and benefits. Zonio appealed to the National Labor Relations Commission (NLRC),
which modified the Labor Arbiter's decision, granting him additional claims. The Court of Appeals (CA)
later deleted the awards for overtime and holiday pay, prompting Zonio to file a petition for review.

Issue: Whether or not Zonio was entitled to overtime pay, holiday and rest day premiums, and night shift
differentials, which the CA had deleted from the NLRC's ruling.

Ruling: The Supreme Court granted Zonio's petition in part, ruling that he was entitled to overtime pay
and night shift differentials. The Court emphasized that the burden of proof for overtime and holiday pay
lies with the employee, but Zonio had sufficiently demonstrated his claims through logbook entries,
despite the entries not being countersigned by the employer. The case was remanded to the Labor Arbiter
for the computation of Zonio's monetary award, which would earn legal interest from the finality of the
resolution until full payment. The ruling highlighted the importance of the employer's burden to prove
payment of claims when the employee has established a prima facie case for their entitlement to benefits.

Digest of G.R. No. 176419

Facts of the Case: GMA Network, Inc. (petitioner) filed a petition against its former employees, Carlos P.
Pabriga and others (respondents), challenging the decision of the Court of Appeals which upheld the
ruling of the National Labor Relations Commission (NLRC). The respondents were employed by GMA
Network, Inc. as television technicians and filed a complaint against the company due to poor working
conditions and non-payment of benefits. The Labor Arbiter initially dismissed their complaints for illegal
dismissal and unfair labor practice but ordered the company to pay the respondents their 13th month pay.
The NLRC later reversed this decision, declaring the respondents as regular employees entitled to
separation pay, night shift differentials, and other benefits.

Issue: Whether or not the respondents were regular employees entitled to benefits such as separation pay
and night shift differentials, or if they were merely project employees without such entitlements.

Ruling: The Supreme Court affirmed the decision of the Court of Appeals and the NLRC, ruling that the
respondents were indeed regular employees of GMA Network, Inc. The Court emphasized that the nature
of employment is determined by law, and the activities performed by the respondents were necessary and
desirable in the usual business of the employer. The Court also noted that the failure of the employer to
report the completion of projects and the termination of the respondents' services indicated that they
were not project employees. Consequently, the respondents were entitled to separation pay and night shift
differentials, while the award of attorney's fees was deleted due to lack of justification.

Digest of G.R. No. 164681 (Navarro v. P.V. Pajarillo Liner, Inc.)

Facts of the Case: Bernardino V. Navarro was employed as a bus driver by P.V. Pajarillo Liner, Inc. In
March 1996, he was apprehended for picking up passengers in a non-loading zone, resulting in the
confiscation of his driver's license. Navarro requested the company's Operations Manager to redeem his
license, but the company only secured extensions for the temporary driver's license (TVR) and failed to
retrieve the original license. After being apprehended again in May 1996, Navarro was unable to work
without his license. He subsequently filed a complaint for illegal dismissal, claiming constructive dismissal
due to the company's failure to redeem his license.

Issue: Whether or not Navarro was constructively dismissed and entitled to backwages, given that he was
unable to work due to the loss of his driver's license, which he claimed the company failed to retrieve.

Ruling: The Labor Arbiter ruled in favor of Navarro, ordering his reinstatement with full backwages.
However, the National Labor Relations Commission (NLRC) modified this decision, ordering reinstatement
without backwages, stating that Navarro was equally at fault for not taking proper steps to redeem his
license. The Court of Appeals upheld the NLRC's ruling, concluding that while Navarro was constructively
dismissed, he was not entitled to backwages because he failed to act responsibly in retrieving his license.
The Supreme Court affirmed the decision of the Court of Appeals, emphasizing that the burden of
economic loss should not be shifted to the employer when the employee did not perform work due to their
own fault.

Digest of G.R. No. 121439

Facts of the Case: Aklan Electric Cooperative Inc. (AKELCO) was involved in a dispute with the National
Labor Relations Commission (NLRC) regarding the unpaid wages of 165 employees, including Rodolfo M.
Retiso. The employees claimed wages for the period from June 16, 1992, to March 18, 1993. The Labor
Arbiter initially dismissed their complaints, but the NLRC reversed this decision, ordering AKELCO to pay
the employees. AKELCO then filed a petition for certiorari with the Supreme Court, arguing that the
evidence presented by the employees was insufficient to prove that they had rendered services during the
claimed period, as the company's official business office had been transferred to another location.

Issue: Whether or not the NLRC committed grave abuse of discretion in reversing the Labor Arbiter's
decision and ordering AKELCO to pay the employees for the period in question, despite the company's
claim that the employees did not work during that time.

Ruling: The Supreme Court granted AKELCO's petition, ruling that the evidence presented by the
employees was inadequate to establish that they had actually rendered services during the disputed
period. The Court found that the employees did not work during this time, as the official business
operations had been moved to Kalibo, Aklan. Consequently, the NLRC's decision was reversed and set
aside, and the employees' claims for unpaid wages were dismissed. The Court emphasized that without
proof of actual work performed, the principle of "no work, no pay" applied, and thus the employees were
not entitled to the claimed wages.

Digest of G.R. No. 100701

Facts of the Case: The case involves a complaint filed by the Producers Bank Employees Association
against Producers Bank of the Philippines, alleging several issues including the diminution of benefits,
non-compliance with Wage Order No. 6, and non-payment of holiday pay. Initially, the Labor Arbiter
dismissed the complaint, but the National Labor Relations Commission (NLRC) reversed this decision,
granting the employees' claims. The bank, which was under conservatorship and facing financial distress,
sought to nullify the NLRC's decision, arguing that the bonuses were discretionary and that its financial
condition justified changes to employee benefits.

Issue: Whether or not the bank was justified in altering employee benefits, including bonuses and holiday
pay, due to its financial difficulties, and whether the NLRC erred in ruling against the bank's claims.

Ruling: The Supreme Court ruled in favor of the bank, stating that the bonuses were discretionary and not
demandable. The Court acknowledged the bank's financial condition as a valid reason for modifying
employee benefits. It found that the bank had complied with the requirements of Wage Order No. 6 and
Article 94 of the Labor Code regarding holiday pay. The NLRC's ruling on damages was upheld, but the
Court set aside the NLRC's decision regarding the other claims, emphasizing that an employer cannot be
compelled to provide benefits it cannot afford, especially in times of financial distress.

Digest of G.R. No. 179146

Facts of the Case: The case involves the Holy Child Catholic School, which filed a petition for review on
certiorari against the Secretary of the Department of Labor and Employment (DOLE) and the labor union
representing its employees. The dispute arose from the Secretary's decision to set aside the Med-Arbiter's
denial of a petition for certification election filed by the labor union. The union's petition claimed that it
represented a mixed group of employees, including both supervisory and rank-and-file personnel, and
argued that the school was unorganized, lacking a certified bargaining agent. The school contended that
the inclusion of supervisory employees in the union rendered it illegitimate and that there was no
community of interest between the teaching and non-teaching staff.

Issue: Whether or not the labor organization, which included supervisory employees, could be considered
a legitimate labor organization entitled to file a petition for certification election, and whether the
determination of an appropriate bargaining unit was a factual issue to be resolved in an
inclusion-exclusion proceeding.

Ruling: The Supreme Court upheld the decision of the Court of Appeals, affirming the Secretary's ruling
that the inclusion of supervisory employees did not divest the union of its status as a legitimate labor
organization. The Court emphasized that the determination of an appropriate bargaining unit is a factual
issue best resolved in an inclusion-exclusion proceeding. The ruling reinforced the principle that the
employer's role in certification elections is limited, and the will of the employees should be respected in
determining their representation. The Court ultimately directed the conduct of separate certification
elections for the teaching and non-teaching personnel, recognizing the differences in their roles and
interests.

Case Digest: Heritage Hotel Manila vs. Secretary of Labor and Employment (G.R. No. 172132)

Facts of the Case: The Heritage Hotel Manila contested the certification election sought by the National
Union of Workers in the Hotel, Restaurant and Allied Industries-Heritage Hotel Manila Supervisors Chapter
(NUWHRAIN-HHMSC) to represent its supervisory employees. The hotel argued that the certification
election should not proceed due to the pendency of its petition to cancel the union's registration. The
hotel's petition for cancellation was based on allegations that the union had a mixed membership (i.e., it
included both supervisory and managerial employees) and that the union failed to comply with certain
reportorial requirements.

Issue: Whether or not the pending petition for the cancellation of the union's registration should bar or
suspend the conduct of the certification election.

Ruling: The Supreme Court held that the pending petition for the cancellation of the union's registration
should not bar the conduct of the certification election. The Court emphasized that a certification election
is the sole concern of the employees, and the employer is considered a mere bystander with no legal
standing to interfere in the process. The Court also stated that only a final order of cancellation of the
union's registration can prevent the union from exercising its rights as a legitimate labor organization,
including the right to petition for a certification election.

Case Digest: National Organization of Trade Unions vs. Secretary of Labor (G.R. No. L-42561)

Facts of the Case: The National Organization of Trade Unions (NORTU) was the recognized bargaining
agent of the employees. The Associated Labor Unions (ALU) filed a petition for a certification election
during the ongoing negotiations between NORTU and the employer for a renewal of their collective
bargaining agreement (CBA). NORTU opposed the petition, arguing that the certification election should
not proceed while negotiations for a new CBA were ongoing. The Bureau of Labor Relations (BLR) ordered
the conduct of a certification election.

Issue:
1.​ Whether or not the Director of the Bureau of Labor Relations had the authority to order a
certification election when the recognized bargaining agent was in the process of negotiating a
renewed collective bargaining agreement with the employer.
2.​ Whether or not the pendency of negotiations to conclude a new CBA constitutes a bar to the
filing of a petition for a certification election.
Ruling:
1.​ The Supreme Court upheld the order for a certification election.
2.​ The Court ruled that the pendency of negotiations for a new CBA does not bar the filing of a
petition for a certification election. The Court emphasized that under the Labor Code, a
certification election is only barred if an election has been held within the past twelve months, or
there exists a certified collective bargaining agreement. Since neither of these conditions existed,
the certification election was validly ordered.

Case Digest: Benson Industries Employees Union vs. Benson Industries, Inc. (G.R. No. 200746)

Facts of the Case: Benson Industries, Inc. notified its employees of its closure due to financial losses. The
employees, through their union, the Benson Industries Employees Union-ALU-TUCP, and individual
employees, received separation pay. The employees, however, claimed additional separation pay based
on a provision in their Collective Bargaining Agreement (CBA) which provided for a higher amount of
separation pay than what was initially paid. Benson Industries argued that it was not obligated to pay the
additional amount due to its financial losses.

Issue: Whether or not Benson Industries, Inc. was obligated to pay the additional separation benefits as
provided in the Collective Bargaining Agreement (CBA), despite its claim of financial distress.

Ruling: The Supreme Court ruled in favor of the employees. The Court held that the CBA is the law
between the parties. Since the CBA provided for a specific amount of separation pay, Benson Industries,
Inc. was obligated to pay that amount, even if the closure was due to financial losses. The Court
emphasized that financial hardship does not excuse an employer from fulfilling its contractual obligations
under a CBA, unless the CBA itself provides for such an exemption.

Case Digest: Goya Inc. vs. Goya Inc. Employees Union (G.R. No. 170054)

Facts of the Case: Goya, Inc. and Goya, Inc. Employees Union entered into a Collective Bargaining
Agreement (CBA) that contained a provision on a union shop clause. The union shop clause required all
new employees to become members of the union as a condition of continued employment. Several
employees refused to join the union, leading the Union to demand their termination from Goya, Inc. Goya,
Inc. refused to terminate the employees, citing their right to freedom of association.

Issue: Whether or not Goya, Inc. was obligated to terminate the employees who refused to join the union,
pursuant to the union shop clause in the CBA.

Ruling: The Supreme Court ruled in favor of Goya, Inc. The Court held that while union shop clauses are
valid, they cannot be enforced to violate an employee's right to freedom of association. The Court
emphasized that employees have the right to choose whether or not to join a union, and this right cannot
be curtailed by a CBA provision.

Digest for G.R. No. 200487

Facts of the Case: Bigg's Inc., a chain of restaurants in Naga City, Camarines Sur, employed union
members represented by their union president, Jay Boncacas. The union staged two strikes: a "sit-down
strike" on February 16, 1996, and another strike on March 5, 1996. The February 16 strike was declared
illegal due to non-compliance with procedural requirements under the Labor Code, such as failure to file a
Notice of Strike with the National Conciliation and Mediation Board (NCMB) and observe the cooling-off
period. The March 5 strike, while procedurally compliant, was also declared illegal because union members
committed prohibited acts, including forming human barricades, throwing stones at delivery vans, and
obstructing ingress and egress from company premises. Bigg's dismissed union officers and members for
their participation in the strikes. The union officers were found to have instigated the illegal strikes, while
the union members were dismissed despite no evidence of their participation in prohibited acts. The Labor
Arbiter (LA) ruled that the strikes were illegal and upheld the dismissal of union officers. However, the LA
ordered the reinstatement of union members who did not commit illegal acts. The Court of Appeals (CA)
affirmed the LA's decision, leading to the filing of a petition for review on certiorari before the Supreme
Court.

Issues:
1.​ Whether the strikes conducted by the union were illegal.
2.​ Whether the dismissal of union officers and members was valid.

Ruling:
1.​ The Supreme Court upheld the LA's and CA's findings that both strikes were illegal. The February
16, 1996 strike was illegal due to non-compliance with procedural requirements under Article 263
of the Labor Code, such as filing a Notice of Strike, observing the cooling-off period, and
conducting a strike vote. The March 5, 1996 strike, while procedurally compliant, was rendered
illegal because of prohibited acts committed by union members, including violence, obstruction,
and intimidation.
2.​ The dismissal of union officers, including Boncacas, was upheld as valid. The Court found that
they instigated and participated in the illegal strikes, which is a ground for termination under
Article 279 (formerly Article 264) of the Labor Code. However, the dismissal of union members
who did not participate in prohibited acts during the strikes was declared invalid. The Court
ordered their reinstatement, as there was no evidence of their involvement in the illegal activities.
Case Digest: Philippines Inter-Fashion, Inc. vs. NLRC (G.R. No. L-59847)

Facts of the Case: Employees of Philippines Inter-Fashion, Inc. formed a union, the Philippine
Inter-Fashion Workers Union, and affiliated with NAFLU. The company announced retrenchments.
Employees staged a strike, and the Ministry of Labor issued a Return to Work Order, which was initially
ignored. The company applied for the termination of the striking employees. Some employees returned to
work, but 114 employees did not.

Issue: Whether the affected employees were entitled to reinstatement and backwages.

Ruling: The Supreme Court found that both the employer (Philippines Inter-Fashion, Inc.) and the
employees engaged in illegal actions (illegal lockout and illegal strike, respectively). The Court upheld the
reinstatement of the 114 employees but denied their claim for backwages. The Court applied the "no work,
no pay" rule, given the employees' participation in the illegal strike.

Case digest of G.R. No. 166879

Facts of the Case: A. Soriano Aviation entered into a Collective Bargaining Agreement (CBA) with the
Employees Association of A. Soriano Aviation, which included a "No-Strike, No-Lock-out" clause. On legal
holidays (May 1, May 12, and June 12, 1997), eight mechanics, who were members of the Union, refused to
render overtime work. The company responded by suspending the mechanics for 30 days and filed a
complaint for illegal strike. The Union, in turn, filed a Notice of Strike, alleging unfair labor practices by the
company, including union busting and illegal dismissal of a union officer. The strikes were declared illegal
due to the Union's illegal actions, which included harassment and the use of placards and banners that
accused the company of criminal negligence.

Issues:
1.​ Whether or not the strike staged by the employees was illegal due to the commission of illegal
acts and the violation of the "No-Strike, No-Lockout" clause in the CBA.
2.​ Whether or not the individual employees lost their employment status due to their participation in
the illegal strike.

Ruling:
1.​ The Supreme Court ruled that the strikes were illegal because they were based on non-strikeable
issues and involved illegal actions by the Union members, such as harassment and intimidation.
The Court emphasized that even if the purpose of a strike is valid, it may still be declared illegal if
the means employed are illegal, citing Article 264 of the Labor Code, which prohibits violence,
intimidation, and coercion during strikes.
2.​ The Court affirmed the decision of the National Labor Relations Commission (NLRC) that the
individual respondents lost their employment status due to their participation in the illegal strike
and the commission of illegal acts during the strike.

Capitol Medical Center, Inc. v. Trajano, et al., G.R. No. 155690, June 30, 2005

Facts of the Case: Capitol Medical Center, Inc. (petitioner) is a hospital that faced a labor dispute with its
employees represented by the Capitol Medical Center Employees Association-AFW (respondent). The
union requested negotiations for a Collective Bargaining Agreement (CBA) on October 2, 1997, but the
hospital refused, questioning the union's legitimacy. In response, the union filed a notice of strike on
October 29, 1997, alleging that the hospital's refusal to bargain constituted unfair labor practice. A strike
was staged on November 28, 1997, prompting the Secretary of the Department of Labor and Employment
to assume jurisdiction over the dispute and order all striking workers to return to work. The hospital's
petition for the cancellation of the union's certificate of registration was denied by the Regional Director
of the Bureau of Labor Relations.
Issue: Whether or not the Secretary of Labor had the authority to assume jurisdiction over the labor
dispute and order the hospital to engage in collective bargaining despite the pending petition for
cancellation of the union's registration.

Ruling: The Supreme Court upheld the decision of the Court of Appeals, affirming the Secretary of Labor's
authority to assume jurisdiction over the labor dispute. The Court ruled that the Secretary's power to
assume jurisdiction includes resolving all questions and controversies arising from the labor dispute, which
is essential for maintaining industrial peace, especially in industries indispensable to national interest. The
Court emphasized that the mere pendency of a petition for cancellation of the union's registration does
not preclude the collective bargaining process. The hospital was mandated to negotiate with the union as
long as the union's certificate of registration remained valid. The decision reinforced the principle that the
Secretary of Labor's discretion in labor disputes is broad and does not require prior notice or hearing to
exercise jurisdiction.

Tiu, et al. v. National Labor Commission, et al., G.R. No. 123276 (1997)

Facts of the Case: In this case, petitioners Mario Tiu and Jonathan Hayuhay filed a petition for certiorari
against the National Labor Commission (NLRC) and Republic Broadcasting System, Inc. (Channel 7)
challenged the NLRC's decision that declared a strike held by the GMA Channel 7 Employees Union
(GMAEU) as illegal. The strike, which occurred on August 2, 1991, was initiated by the union in response to
alleged unfair labor practices by the employer, including violations of the collective bargaining agreement.
The labor arbiter ruled that the strike was illegal, leading to the dismissal of fourteen union officers,
including the petitioners, who participated in the strike.

Issue: Whether or not the NLRC committed grave abuse of discretion in upholding the labor arbiter's
decision that the strike was illegal.

Ruling: The Supreme Court dismissed the petition, affirming the NLRC's ruling. The Court found that the
notice of strike filed by the GMAEU contained vague and general allegations that did not substantiate
claims of unfair labor practices. The Court emphasized that the union had the burden of proof to provide
substantial evidence supporting its allegations, which it failed to do during the conciliation meetings. The
Court noted that the union's refusal to provide specific details regarding the alleged unfair practices
further weakened its position. The Court concluded that there were no strikeable issues to support the
union's actions, as the alleged violations did not constitute unfair labor practices under the law.
Consequently, the Court upheld the labor arbiter's decision that the strike was illegal and that the union
officers who participated in it had validly lost their employment status.

Mendoza v. Borela, et al., G.R. No. 201595, January 25, 2016

Facts of the Case: Allan M. Mendoza was a member of the Manila Water Employees Union (MWEU), a
labor organization representing employees of the Manila Water Company. Mendoza faced penalties for
non-payment of increased union dues, which led to his suspension and eventual expulsion from the union.
He was not given the opportunity to appeal his suspension and expulsion as per the union's Constitution
and By-Laws, which required a majority vote from the General Membership Assembly for such actions.
Mendoza filed a complaint against the MWEU officers for unfair labor practices, claiming that they
violated his rights as a union member by not following proper procedures in suspending and expelling him.

Issues: Whether or not the actions of the MWEU officers constituted unfair labor practices under Article
249 of the Labor Code, specifically regarding the restraint or coercion of employees in the exercise of their
right to self-organization.

Ruling: The Supreme Court partially granted Mendoza's petition, finding that the MWEU officers were
guilty of unfair labor practices. The Court ruled that Mendoza's suspension and expulsion were illegal as
the required procedures for such actions were not followed, violating his rights as a union member. The
Court ordered the MWEU officers to pay Mendoza moral damages, exemplary damages, and attorney's
fees, emphasizing that the failure to adhere to the union's own rules constituted a breach of Mendoza's
rights.

Digest of G.R. No. 175002

Facts of the Case: The case involves Pepsi-Cola Products Philippines, Inc. (Pepsi) and its retrenchment
program, which led to the dismissal of several employees who were members of the Leyte Pepsi-Cola
Employees Union-Associated Labor Union (LEPCEU-ALU). The National Labor Relations Commission
(NLRC) initially ruled in favor of Pepsi, but the Court of Appeals (CA) later reversed this decision, declaring
the retrenchment illegal and finding Pepsi guilty of unfair labor practices (ULP). Pepsi then filed a petition
for review, contesting the CA's ruling.

Issues:
1.​ Whether or not the CA could reverse the factual findings of the NLRC.
2.​ Whether or not the retrenchment of the employees was valid.
3.​ Whether or not Pepsi committed ULP in the form of union busting.
4.​ Whether or not the execution of quitclaims by the employees constituted a final settlement of
their claims.

Ruling: The Supreme Court granted Pepsi's petition, reinstating the NLRC's decision. The Court found that
Pepsi's retrenchment program was valid, as it complied with the necessary legal requirements, including
providing written notice to the affected employees and the Department of Labor and Employment (DOLE)
at least one month prior to the retrenchment. The Court also ruled that the quitclaims signed by the
employees did not preclude them from filing claims with the NLRC, as these were executed with the
understanding that they were without prejudice to future claims. Ultimately, the Court upheld the validity
of the retrenchment and dismissed the claims of unfair labor practices against Pepsi, concluding that the
company acted in good faith and did not engage in union busting.

Digest of G.R. No. 114333

Facts of the Case: Reynaldo M. Rueda was employed by Pantranco North Express, Inc. as a bus
conductor and later promoted to Line Inspector-I. He was dismissed following a quarrel with a co-worker,
which led to a stabbing incident. Although Rueda claimed self-defense, the company initially
recommended his dismissal. However, after he suffered a vehicular accident and was diagnosed with
tuberculosis, the company opted to retire him due to medical reasons instead of proceeding with the
dismissal. Rueda contested this retirement, claiming it was effectively a constructive dismissal. He filed a
complaint for illegal dismissal, reinstatement, backwages, damages, and attorney’s fees.

Issue: Whether or not Rueda's dismissal was illegal and whether he was entitled to backwages and
separation pay.

Ruling: The National Labor Relations Commission (NLRC) ruled that Rueda's dismissal was illegal, as the
company had abandoned the grounds of serious misconduct when it chose to retire him due to health
issues. The NLRC ordered the company to pay Rueda backwages and separation pay, computed from his
original employment date in 1956 until his alleged constructive dismissal in 1988. The Supreme Court
affirmed the NLRC's decision but modified the computation of Rueda's separation pay, ruling that it
should be based on his reemployment date in 1981 until the end of his sick leave in 1989, thus ensuring
protection for labor rights under the Labor Code

Digest of G.R. No. 212616

Facts of the Case: The case involves a petition for review on certiorari filed by Distribution & Control
Products, Inc. and its president, Vincent M. Tiamsic, against Jeffrey E. Santos, a company driver. Santos
filed a complaint for constructive illegal dismissal after being placed under preventive suspension due to
alleged involvement in the theft of electrical products. The labor tribunals found that the petitioners failed
to prove just cause for Santos's termination and did not afford him procedural due process. The Court of
Appeals affirmed the labor tribunal's decision, leading to the petitioners' appeal to the Supreme Court.

Issue: Whether or not the Court of Appeals erred in affirming the labor tribunal's ruling that Santos was
illegally dismissed, given the petitioners' claims of just cause based on loss of trust and confidence.

Ruling: The Supreme Court upheld the findings of the lower courts, ruling that the petitioners did not meet
the burden of proof required to justify Santos's dismissal. The Court emphasized that an employer must
provide substantial evidence to support claims of just cause for termination. Additionally, the Court
reiterated the importance of procedural due process, which includes providing the employee with two
written notices and an opportunity to be heard. Since the petitioners failed to establish a valid cause for
dismissal and did not comply with procedural requirements, the Court affirmed the decision of the Court
of Appeals, which ordered Santos's reinstatement and payment of back wages.

Case Digest: Samson vs. Central Azucarera De Bais, Inc. (G.R. No. 243855)

Facts of the Case: Pat C. Samson and Paul Philip M. Baena were employees of Central Azucarera De Bais,
Inc. (CAB). Samson and Baena tested positive for drug use during a company drug test. CAB dismissed
them from employment due to the positive drug test results. Samson and Baena contested their dismissal.
The Court of Appeals ruled in favor of CAB, upholding the validity of the dismissal.

Issue: Whether or not CAB was justified in dismissing Samson and Baena for testing positive for drug use.

Ruling: The Supreme Court affirmed the Court of Appeals' decision. The Supreme Court held that CAB was
justified in dismissing Samson and Baena. The Court ruled that drug use constitutes serious misconduct,
which is a just cause for termination of employment.

Case Digest: The Orchard Golf and Country Club vs. Francisco (G.R. No. 178125)

Facts of the Case: Amelia R. Francisco was employed by The Orchard Golf and Country Club as the Club
Accountant, heading the General Accounting Division. Francisco failed to draft a letter to SGV & Co. as
instructed by her superior, despite repeated reminders. Francisco was suspended for 15 days without pay
due to this failure. Francisco questioned the propriety of her superior's actions, but her complaints were
dismissed. Francisco later filed a complaint regarding alleged irregularities in the approval and release of
Club checks. Francisco was placed on forced leave and subsequently transferred to the Cost Accounting
Section. Francisco filed a complaint for illegal dismissal, which she later amended to include illegal
suspension and constructive dismissal.

Issue: Whether or not the transfer of Francisco from Club Accountant to Cost Controller amounted to a
demotion and constructive dismissal.

Ruling: The Supreme Court ruled that Francisco's transfer was a demotion and constituted constructive
dismissal. The Court found that the transfer was made without just cause and proper notice, effectively
demoting her from a managerial role to a supervisory one. The Court emphasized that constructive
dismissal occurs when an employee's working conditions become so intolerable that they are compelled to
resign.

Digest of G.R. No. 217101

Facts of the Case: Monica C. Palco filed a complaint against LBC Express-Vis, Inc. for constructive
dismissal after experiencing sexual harassment from her supervisor, Arturo A. Batucan. The harassment
included inappropriate comments and physical advances, culminating in an attempted kiss. Despite
reporting the incidents to management, LBC failed to take prompt and effective action. Palco felt unsafe
and ultimately resigned, believing she had no choice due to the hostile work environment. The Labor
Arbiter ruled in her favor, awarding her backwages, separation pay, moral damages, and attorney's fees.
LBC's appeal was based on claims of insufficient evidence and the argument that Batucan acted
independently.

Issue: Whether or not LBC Express-Vis, Inc. should be held liable for constructive dismissal due to the
hostile work environment created by Batucan's actions and the company's failure to act promptly on
Palco's complaints.

Ruling: The Supreme Court ruled that LBC was liable for constructive dismissal. It emphasized that the
employer's failure to act on the sexual harassment complaint created a hostile work environment, making
Palco's continued employment unreasonable. The Court affirmed the lower courts' decisions, holding LBC
solidarily liable for damages, including separation pay, backwages, moral damages, and attorney's fees,
due to its insensitivity and inaction regarding Palco's complaints of sexual harassment

Digest of G.R. No. 177114 (Peñaflor v. Outdoor Clothing Manufacturing Corporation)

Facts of the Case: Manolo A. Peñaflor was employed as the probationary Human Resource Department
(HRD) Manager at Outdoor Clothing Manufacturing Corporation. He claimed he was constructively
dismissed due to a hostile work environment following the company's downsizing program, which included
the dismissal of his staff and the appointment of a new HRD manager, Edwin Buenaobra. Although
Outdoor Clothing argued that Peñaflor voluntarily resigned, the court found that his resignation was a
response to the intolerable conditions created by the company, particularly the appointment of another
person to his position. Peñaflor filed a complaint for illegal dismissal, which the Labor Arbiter initially ruled
in his favor, but the National Labor Relations Commission (NLRC) later reversed this decision. Peñaflor
appealed to the Court of Appeals, which affirmed the NLRC's ruling.

Issue: Whether or not Peñaflor's resignation was voluntary or a result of constructive dismissal due to the
hostile working conditions imposed by Outdoor Clothing.

Ruling: The Supreme Court ruled in favor of Peñaflor, finding that he was indeed constructively dismissed.
The Court emphasized that the burden of proof lies with the employer to demonstrate that the resignation
was voluntary. It noted that Peñaflor's resignation was a reaction to the unacceptable appointment of
Buenaobra and the adverse treatment he experienced. The Court reinstated the Labor Arbiter's decision,
ordering Outdoor Clothing to pay Peñaflor backwages, separation pay, and other damages, while
clarifying that the corporate officers were not jointly liable as no malice or bad faith was proven against
them. The ruling highlighted the principle that doubts in labor disputes should be resolved in favor of the
employee

Digest of G.R. No. 174208 (Morales v. Harbour Centre Port Terminal, Inc.)

Facts of the Case: Jonathan V. Morales was initially hired by Harbour Centre Port Terminal, Inc. (HCPTI)
as an Accountant and later promoted to Division Manager of the Accounting Department. Following a
corporate relocation, he was reassigned to a position in Operations Cost Accounting, which he viewed as
a demotion since the new role was not included in the company's plantilla. Morales protested this
reassignment, claiming it constituted constructive dismissal. He subsequently filed a complaint for
constructive dismissal, moral and exemplary damages, and attorney’s fees. The Labor Arbiter dismissed
his complaint, ruling that the reassignment was a valid exercise of management prerogative. However, the
National Labor Relations Commission (NLRC) reversed this decision, finding that the reassignment was
indeed a demotion. HCPTI then appealed to the Court of Appeals, which ruled in favor of HCPTI, stating
that Morales had not been constructively dismissed.
Issue: Whether or not Morales' reassignment constituted constructive dismissal, which occurs when an
employee's continued employment becomes impossible or unreasonable due to an employer's actions.

Ruling: The Supreme Court ruled in favor of Morales, stating that his reassignment was a demotion and
constituted constructive dismissal. The Court emphasized that the employer bears the burden of proving
that any transfer or reassignment is for valid and legitimate reasons. HCPTI failed to demonstrate that the
reassignment was justified, as it involved a transfer from a managerial position to one that was not
recognized in the company's plantilla. Consequently, the Court reversed the decision of the Court of
Appeals and reinstated the NLRC's ruling, which ordered HCPTI to pay Morales back wages and
separation pay for his constructive dismissal.

Digest of G.R. No. 254465: Bartolome v. Toyota Quezon Avenue, Inc.

Facts of the Case: Jonathan Dy Chua Bartolome was employed as a marketing professional at Toyota
Quezon Avenue, Inc. (TQAI). He claimed he was constructively dismissed due to a hostile work
environment created by management, which included being stripped of accounts, receiving derogatory
remarks, and being pressured to resign. After a series of incidents, including a suspension for habitual
absences and unsavory comments from management, Bartolome felt compelled to resign. He filed a
complaint for illegal dismissal and money claims, which the Labor Arbiter initially ruled in his favor,
awarding him backwages, separation pay, and damages. However, the Court of Appeals reversed this
decision, leading Bartolome to seek a review from the Supreme Court.

Issue: Whether or not Bartolome was constructively dismissed from his employment, which would entitle
him to the claims he filed against TQAI.

Ruling: The Supreme Court ruled in favor of Bartolome, reversing the Court of Appeals' decision. The
Court held that Bartolome was indeed constructively dismissed, as the actions of TQAI's management
created an unbearable work environment. The Court reinstated the Labor Arbiter's decision, ordering TQAI
to pay Bartolome backwages, separation pay, commissions, moral and exemplary damages, and
attorney's fees. The ruling emphasized that constructive dismissal occurs when an employee's working
conditions become intolerable, leaving them no choice but to resign, thus protecting the dignity of labor

Digest of G.R. No. 158693

Facts of the Case: Jenny and Virgilio Agabon were employed by Riviera Home Improvements, Inc. as
gypsum board and cornice installers. They were dismissed on February 23, 1999, for allegedly abandoning
their work. The Labor Arbiter initially ruled that their dismissal was illegal and ordered the company to pay
them backwages and other monetary claims. However, the National Labor Relations Commission (NLRC)
reversed this decision, stating that the Agabons had indeed abandoned their employment. The Court of
Appeals upheld the NLRC's finding of abandonment but ordered the payment of certain monetary claims,
including holiday pay and service incentive leave pay.

Issue: Whether or not the dismissal of the Agabons constituted illegal dismissal and whether they were
entitled to their monetary claims despite the finding of abandonment.

Ruling: The Supreme Court affirmed the Court of Appeals' decision, ruling that the dismissal was for just
cause due to abandonment of work. However, it imposed sanctions on the employer for failing to comply
with statutory due process, ordering Riviera Home Improvements to pay nominal damages to the
Agabons. The Court upheld the monetary claims awarded by the Court of Appeals, including holiday pay,
service incentive leave pay, and a portion of the 13th month pay, while also emphasizing the importance
of due process in employment termination.
Digest of G.R. No. 223854

Facts of the Case: Robustan, Inc. (Petitioner) filed a petition against the Court of Appeals and Wilfredo
Wagan (Respondent), challenging a decision that upheld the National Labor Relations Commission's
(NLRC) findings that Wagan was illegally dismissed. Wagan, employed as a service engineer, was
terminated for alleged "violation of trust and confidence," "inefficient work performance," and the loss of
company property. Initially, the Labor Arbiter dismissed Wagan's claim of illegal dismissal, but the NLRC
reversed this decision, leading to an appeal by Robustan to the Court of Appeals, which affirmed the
NLRC's ruling with modifications, granting Wagan backwages and separation pay.

Issue: Whether or not Wagan's dismissal was legal, specifically if there was just cause for termination
based on the claims of loss of trust and confidence, gross negligence, and abandonment of work.

Ruling: The Supreme Court upheld the Court of Appeals' decision, affirming that Robustan failed to prove
just cause for Wagan's dismissal. The Court found that Wagan did not occupy a position of trust and
confidence, and the evidence presented did not substantiate claims of gross negligence or abandonment.
The Court emphasized that the burden of proof lies with the employer to establish just cause for
termination, which Robustan did not meet. Thus, the dismissal was deemed illegal, and the Court affirmed
the award of backwages and separation pay to Wagan.

Digest of G.R. No. 186614

Facts of the Case: Ronald Valderama was employed as a security guard by Nationwide Security and
Allied Services, Inc. He was assigned to the Philippine Heart Center until January 30, 2006, when he was
relieved from his post and not given a new assignment. On August 2, 2006, Valderama filed a complaint
for constructive dismissal and nonpayment of 13th month pay against his employer. The company claimed
that Valderama voluntarily resigned, but he argued that he was constructively dismissed due to being left
without an assignment for an extended period.

Issue: Whether or not Valderama was constructively dismissed from his employment or if he had
voluntarily resigned.

Ruling: The Supreme Court ruled in favor of Valderama, affirming the decision of the Court of Appeals
which reinstated the Labor Arbiter's ruling that he was constructively dismissed. The Court highlighted that
Valderama remained on "floating status" for more than six months without a new assignment, which
constituted constructive dismissal. The employer failed to provide credible evidence to support their claim
of voluntary resignation, and the Court emphasized that the filing of a complaint for illegal dismissal is
inconsistent with the assertion of resignation. Thus, the Court ordered Valderama's reinstatement and the
payment of backwages, affirming the lower court's decision.

Digest of G.R. No. 183915 (Bilbao v. Saudi Arabian Airlines)

Facts of the Case: Ma. Joy Teresa O. Bilbao, a former flight attendant for Saudi Arabian Airlines (Saudia),
filed a complaint for illegal dismissal after she resigned from her position. The resignation occurred after
she was informed of her transfer from the Manila office to Jeddah, which she claimed was a prelude to
termination. Bilbao argued that her resignation was not voluntary, asserting that she was coerced into
signing a pre-typed resignation letter. After her resignation, she signed an Undertaking acknowledging
receipt of her end-of-service award and releasing Saudia from any further claims. The Labor Arbiter
initially ruled in her favor, declaring her dismissal illegal. However, the National Labor Relations
Commission (NLRC) reversed this decision, stating that her resignation was voluntary.

Issue: Whether or not Bilbao's resignation was voluntary or if it constituted illegal dismissal due to
coercion by Saudia.
Ruling: The Supreme Court upheld the findings of the NLRC and the Court of Appeals, affirming that
Bilbao voluntarily resigned from her employment. The Court noted that her resignation letter and the
circumstances surrounding her departure indicated no coercion. The Court emphasized that her
educational background and the absence of evidence supporting her claims of intimidation further
substantiated the conclusion that her resignation was a voluntary act. Consequently, her claims for
reinstatement, backwages, and damages were denied, and the decision of the lower courts was affirmed.

Digest of G.R. No. 229920 (Mamaril v. The Red System Company, Inc.)

Facts of the Case: Samuel Mamaril was employed as a delivery service representative by The Red System
Company, Inc. He was dismissed after multiple violations of the company's safety rules, which included
failing to engage the hand brake and put a tire choke on parked trucks, leading to accidents that caused
damage to company property. Mamaril admitted to these violations during an administrative hearing but
claimed that his dismissal was unjust and sought reinstatement along with back wages and damages. The
Labor Arbiter dismissed his complaint for illegal dismissal, stating that Mamaril's actions constituted
willful disobedience of company rules. The National Labor Relations Commission (NLRC) affirmed this
decision but awarded him his 13th month pay and service incentive leave pay due to the employer's failure
to prove payment.

Issue: Whether or not Mamaril was illegally dismissed and whether he was subjected to a double penalty
for being placed under preventive suspension and subsequently dismissed.

Ruling: The Supreme Court upheld the decisions of the lower courts, affirming that Mamaril's dismissal
was valid due to his willful disobedience of lawful orders. The Court ruled that the preventive suspension
was justified as it was necessary to protect the company's interests. It emphasized that the employer has
the right to dismiss an employee for serious misconduct, and Mamaril's repeated violations warranted his
termination. The Court also confirmed the NLRC's award of 13th month pay and service incentive leave
pay, as the employer failed to provide evidence of payment. The ruling highlighted the balance between
protecting employee rights and the employer's prerogative to manage operations effectively.

Case Digest: Rodriguez vs. Sintron Systems, Inc. (G.R. No. 240254)

Facts of the Case: Rodessa Quitevis Rodriguez was hired by Sintron Systems, Inc. (SSI) as a Sales
Coordinator. A conflict arose when SSI asked Rodriguez to sign a training agreement requiring her to stay
with the company for three years or pay a penalty, which she refused. Rodriguez alleged that she was
forced to go on leave due to the abusive behavior of SSI's president. Rodriguez filed a complaint for
constructive illegal dismissal, non-payment of Service Incentive Leave (SIL) pay, separation pay,
damages, and attorney's fees. SSI denied the allegations and claimed that Rodriguez's absences were
unapproved and constituted abandonment of her job.

Issue: Whether or not Rodriguez was illegally dismissed or had abandoned her work.

Ruling: The Supreme Court ruled that Rodriguez was neither dismissed nor had abandoned her work. The
Court held that Rodriguez failed to provide substantial evidence of her dismissal. The Court also found
that SSI failed to prove that Rodriguez intended to abandon her job. The Supreme Court ordered SSI to
reinstate Rodriguez without backwages.

Digest of G.R. No. 226002

Facts of the Case: Lino A. Fernandez, Jr. was a former employee of the Manila Electric Company
(MERALCO), who was terminated in 2000 for allegedly participating in an illegal strike. Following his
dismissal, he filed a case for illegal dismissal and was eventually declared to have been illegally dismissed,
with the Court of Appeals ordering his reinstatement or payment of separation pay if reinstatement was
not feasible. However, disputes arose regarding the computation of his monetary awards, including
backwages and other benefits. Fernandez filed various motions and appeals, which were dismissed by the
National Labor Relations Commission (NLRC). The Court of Appeals affirmed the NLRC's decisions,
prompting Fernandez to file a petition for certiorari with the Supreme Court.

Issue: Whether or not the NLRC committed grave abuse of discretion in denying Fernandez's motions
regarding the computation of his monetary awards and whether he was entitled to reinstatement or
separation pay.

Ruling: The Supreme Court granted Fernandez's petition, reversing the decisions of the Court of Appeals
and the NLRC. The Court remanded the case to the NLRC for further resolution, emphasizing that an
illegally dismissed employee is entitled to reinstatement as a matter of right, with separation pay being an
alternative only under certain circumstances. The Court highlighted the need for a liberal application of
procedural rules to prevent injustice to illegally dismissed employees, thereby allowing Fernandez to
pursue his claims for backwages and benefits

Digest of G.R. No. 221096

Facts of the Case: The case involves Ma. Realiza S. Tanguin, who filed an illegal dismissal complaint
against her employer, Claudia's Kitchen, Inc., and its president, Enzo Squillantini. Tanguin was placed on
preventive suspension on October 26, 2010, due to allegations of forcing her co-employees to buy jewelry
during work hours. Despite being suspended, she was required to submit a written explanation regarding
the allegations. Tanguin claimed she was barred from entering the company premises, while the
petitioners argued that she was still employed and had not been dismissed. The Labor Arbiter ruled that
Tanguin was not illegally dismissed but ordered her unpaid salary to be paid. Tanguin appealed to the
National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's decision but ordered her
reinstatement without backwages. The Court of Appeals modified the NLRC ruling, denying reinstatement
and awarding separation pay instead, citing strained relations.

Issue: Whether or not separation pay could be awarded to Tanguin, who was not dismissed from her
employment.

Ruling: The Supreme Court ruled that Tanguin was not dismissed from her employment, and therefore, she
was not entitled to separation pay. The Court emphasized that the burden of proof lies with the employee
to establish that they were dismissed. Since Tanguin failed to prove her dismissal and her complaint was
deemed premature, the Court ordered her to return to work and for the petitioners to accept her back,
without prejudice to the ongoing investigation against her. The ruling highlighted that separation pay is
only warranted when an employee has been dismissed, and the doctrine of strained relations could not be
applied without factual basis. Thus, the petition was granted, and Tanguin was ordered to return to work
within fifteen days from the receipt of the decision

Digest of G.R. No. 259982

Facts of the Case: Nicolas F. Bobiles, a seafarer employed by Pacific Ocean Manning, Inc. and V. Ships
UK Ltd., suffered a back injury while working on the vessel Nordic Vega. After being repatriated to the
Philippines, he was diagnosed with a severe lumbar spine injury and declared permanently unfit to work as
a seaman. The National Conciliation and Mediation Board (NCMB) awarded him total permanent
disability compensation and attorney's fees, which was modified by the Court of Appeals (CA). The case
revolved around the failure of the company-designated physician to issue a final medical assessment
within the required period, leading to the legal presumption of total and permanent disability.

Issue: Whether or not Bobiles was entitled to attorney's fees in addition to his disability compensation,
considering the applicable provisions of the Labor Code and the Civil Code regarding attorney's fees.
Ruling: The Supreme Court ruled that Bobiles was entitled to total permanent disability compensation of
USD 60,000 but denied the award of attorney's fees. The Court clarified that attorney's fees under Article
111 of the Labor Code are only recoverable in cases of unlawful withholding of wages, which did not apply
in this case. Additionally, the Court found that the provisions of Article 2208(2) and (8) of the Civil Code,
which pertain to litigation expenses related to third parties and workmen's compensation, respectively,
were also inapplicable. The Court emphasized that attorney's fees should not be awarded without a
factual, legal, or equitable justification, leading to the deletion of the attorney's fees from the award. The
decision was modified to include a 6% legal interest per annum on the disability compensation from the
finality of the decision until full payment.

Digest of G.R. No. 253940 (Dolera v. Social Security System)

Facts of the Case: Belinda D.R. Dolera filed a claim for a survivorship pension following the death of her
husband, Leonardo Dolera, who was a member-pensioner of the Social Security System (SSS). The SSS
denied her claim based on Section 13-A(c) of the Social Security Act, which states that primary
beneficiaries must be recognized as of the date of the pensioner's disability. Since Dolera married
Leonardo after he had become disabled, her claim was initially dismissed. Dolera challenged this
provision, arguing it violated her rights under the equal protection and due process clauses of the
Constitution.

Issue: Whether or not the provision "as of the date of disability" in Section 13-A(c) of the Social Security
Law, which disqualified Dolera from being a primary beneficiary, was unconstitutional for violating the
equal protection and due process clauses.

Ruling: The Supreme Court ruled in favor of Dolera, declaring the contested provision void for being
violative of the equal protection and due process clauses of the Constitution. The Court found that the
classification created by the provision was unreasonable and discriminatory against spouses who married
after the pensioner's disability. The Court ordered the SSS to process Dolera’s claim for survivorship
pension, thus reversing the decisions of the lower courts and the Social Security Commission

Digest of G.R. No. 119891 (Sta. Rita v. Court of Appeals, et al.)

Facts of the Case: The case involves Ben Sta. Rita, who was charged with failing to remit contributions to
the Social Security System (SSS) for employees of his company, B. Sta. Rita Co., Inc. The Regional Trial
Court (RTC) initially dismissed the criminal case against him, ruling that the Memorandum of Agreement
between the Department of Labor and Employment (DOLE) and the SSS, which extended social security
coverage to Filipino seafarers on foreign vessels, was null and void. The dismissal was contested by the
People of the Philippines, leading to an appeal to the Court of Appeals.

Issue: Whether or not the Court of Appeals erred in reinstating the criminal case against Sta. Rita after
the RTC had dismissed it. Additionally, the case raised questions about the validity of the Memorandum of
Agreement and whether it effectively amended the Social Security Law.

Ruling: The Supreme Court denied Sta. Rita's petition for review on certiorari, affirming the decision of the
Court of Appeals. The Court held that Sta. Rita's petition was filed late and failed to comply with
procedural requirements. Furthermore, the Court found that the Memorandum of Agreement was valid
and did not constitute an amendment to the law, as it merely facilitated the inclusion of Filipino seafarers
under the SSS coverage. The Court emphasized that the reinstatement of the criminal case did not violate
Sta. Rita's right against double jeopardy since the dismissal was at his own instance. Thus, the Court
upheld the sufficiency of the information filed against him, allowing the prosecution to proceed.