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LABOR STANDARDS TOPIC: Article IV Labor Code GR No. 174631 Uy vs. Centro Ceramica Corporation and/or Sy and Garcia October 19, 2011 NLRC’s finding of illegal dismissal is supported by the totality of evidence and more consistent with logic and ordinary human experience than the common finding of the CA and Labor Arbiter that petitioner informally severed his employment relationship with the company. Crucial factor is the verbal order directly given by Sy, the company president, for petitioner to immediately turn over his accountabilities Uy’s act of turning over the company files and samples is proof of his voluntary informal resignation rather than of the summary dismissal effected by management. Evidence on record suggests that petitioner did not resign; he was orally dismissed by Sy. It is this lack of clear, valid and legal cause, not to mention due process, that made his dismissal illegal, warranting reinstatement and the award of backwages. When there is no showing of a clear, valid and legal cause for the termination of employment, the law considers it a case of illegal dismissal. Furthermore, Article 4 of the Labor Code expresses the basic principle that all doubts in the interpretation and implementation of the Labor Code should be interpreted in favor of the workingman. This principle has been extended by jurisprudence to cover doubts in the evidence presented by the employer and the employee. Thus we have held that if the evidence presented by the employer and the employee are in equipoise, the scales of justice must be tilted in favor of the latter. Ponente: Justice Villarama, Jr. FACTS: Petitioner Uy was hired by respondent company on March 21, 1999, after which, he became a regular employee on May 01, 2000. He alleged that his predicament began when former VP Garcia was re-hired by company in the last quarter of 2001. Incidents involving longtime clients led to a strained relationship between him and Garcia. February 19, 2002, he was informed by his supervisor that he was to assume a new position in the marketing department to which he replied that he will think it over. His friends warned him to be careful saying “Mainit ka kay Garcia”. That same day, he was summoned by Sy and Garcia for a closed-door meeting during which he was informed of the termination of his services due to “insubordination” and advised him to turn over his

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Page 1: Case Briefs on Labor Standards

LABOR STANDARDS TOPIC: Article IV Labor Code

GR No. 174631 Uy vs. Centro Ceramica Corporation and/or Sy and Garcia

October 19, 2011 NLRC’s finding of illegal dismissal is supported by the totality of evidence and more consistent with logic and ordinary human experience than the common finding of the CA and Labor Arbiter that petitioner informally severed his employment relationship with the company. Crucial factor is the verbal order directly given by Sy, the company president, for petitioner to immediately turn over his accountabilities Uy’s act of turning over the company files and samples is proof of his voluntary informal resignation rather than of the summary dismissal effected by management. Evidence on record suggests that petitioner did not resign; he was orally dismissed by Sy. It is this lack of clear, valid and legal cause, not to mention due process, that made his dismissal illegal, warranting reinstatement and the award of backwages.

When there is no showing of a clear, valid and legal cause for the termination of employment, the law considers it a case of illegal dismissal. Furthermore, Article 4 of the Labor Code expresses the basic principle that all doubts in the interpretation and implementation of the Labor Code should be interpreted in favor of the workingman. This principle has been extended by jurisprudence to cover doubts in the evidence presented by the employer and the employee. Thus we have held that if the evidence presented by the employer and the employee are in equipoise, the scales of justice must be tilted in favor of the latter.

Ponente: Justice Villarama, Jr. FACTS: Petitioner Uy was hired by respondent company on March 21, 1999, after which, he became a regular employee on May 01, 2000. He alleged that his predicament began when former VP Garcia was re-hired by company in the last quarter of 2001. Incidents involving longtime clients led to a strained relationship between him and Garcia. February 19, 2002, he was informed by his supervisor that he was to assume a new position in the marketing department to which he replied that he will think it over. His friends warned him to be careful saying “Mainit ka kay Garcia”. That same day, he was summoned by Sy and Garcia for a closed-door meeting during which he was informed of the termination of his services due to “insubordination” and advised him to turn over his

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samples and files immediately. Sy even commented “member ka pa naman ng Singles for Christ pero napakatigas ng ulo mo.” February 21, 2002, Sy summoned him again but prior to this he was informed by his supervisor that Sy will give him all that is due plus goodwill money. However, during his meeting with Sy, he asked for his termination paper to which Sy replied “If that’s what you want I will give it to you. Pag-isipan mo ang gagawin mo dahil kilala mo naman kami we are powerful.” The following day, he turned over company samples, accounts and receivables to his supervisor. Thereafter, he did not report to work anymore. March 06, 2002, an employee of the company presented to him a memorandum about his alleged poor sales performance to which he is being required to submit a written explanation, why the company should not terminate his contract. On March 13, 2002, he received a memorandum about his absence without leave and failure to respond to the March 06 memorandum to which he is being required to submit a written explanation, why the company should not terminate his contract. Respondent thru counsel sent a letter-reply and on March 18, 2002 Petitioner filed a complaint for illegal dismissal against respondent company. Labor Arbiter’s ruling: Company’s favor, it was petitioner who opted not to work, after offering to resign because he could not accept his possible transfer to another department. NLRC’s ruling: Uy’s favor, reversed Labor Arbiter’s decision, Uy’s dismissal was made under questionable circumstances giving weight to his claim that he was being singled out notwithstanding that all sales personnel similarly could not meet the P1.5 million monthly sales quota. CA: Company’s favor, evidence on record supports the Labor Arbiter’s finding that petitioner "informally severed" the employment relationship as manifested by his voluntary transfer of his accountabilities to his supervisor and thereafter his act of not reporting for work anymore. Uy’s motion for reconsideration was denied; hence, this instant petition. ISSUE/S: Uy’s Arguments:

1. CA instead of decreeing his illegal termination based on Sy’s verbal dismissal without just cause and due process; concluded that petitioner voluntarily and informally severed his relation with the company.

2. Agcaoili’s statement is not important because what matters is the action of Sy who dismissed him outright.

3. His act of turning over his accountabilities to his supervisor cannot be considered voluntary on his part as it was done by him knowing that he was already terminated and upon the specific instructions of Sy and Garcia.

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Company’s Arguments: 1. Evidence clearly show that Uy was not dismissed but required merely to explain why he failed to

report for work after meeting the company president. 2. Uy’s act of turning over his accountabilities cannot be proof of his illegal dismissal because it

was done voluntarily in line with his proposed resignation. 3. That when the company was about to conduct investigation on Uy who went AWOL since

February 19, 2002, the latter refused to accept the memos sent to him; thus, confirming that the company was investigating his failure to report for work and giving him all the opportunity to explain his absence.

Whether petitioner was dismissed or voluntarily severed his employment by abandoning his job. DECISION: The court granted Uy’s petition by reversing CA’s decision and reinstating NLRC’s with modifications to the monetary rewards Uy is entitled to.

NLRC’s finding of illegal dismissal is supported by the totality of evidence and more consistent with logic and ordinary human experience than the common finding of the CA and Labor Arbiter that petitioner informally severed his employment relationship with the company. The court is not convinced that after declining his supposed transfer to another department as per the information relayed to him by his supervisor, petitioner would readily turn over his files and samples unless something critical indeed took place in his subsequent closed-door meeting with Sy and Garcia.

Crucial factor is the verbal order directly given by Sy, the company president, for petitioner to immediately turn over his accountabilities Uy’s act of turning over the company files and samples is proof of his voluntary informal resignation rather than of the summary dismissal effected by management. Uy directly confirmed from the company president herself that he was already being dismissed. Evidence on record suggests that petitioner did not resign; he was orally dismissed by Sy. It is this lack of clear, valid and legal cause, not to mention due process, that made his dismissal illegal, warranting reinstatement and the award of backwages. Moreover, the filing of a complaint for illegal dismissal just three weeks later is difficult to reconcile with voluntary resignation. When there is no showing of a clear, valid and legal cause for the termination of employment, the law considers it a case of illegal dismissal. Furthermore, Article 4 of the Labor Code expresses the basic principle that all doubts in the interpretation and implementation of the Labor Code should be interpreted in favor of the workingman. This principle has been extended by jurisprudence to cover doubts in the evidence presented by the employer and the employee. Thus we have held that if the evidence presented by the employer and the employee are in equipoise, the scales of justice must be tilted in favor of the latter. Accordingly, the NLRC’s finding of illegal dismissal must be upheld.

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GR No. 177114 Peñaflor vs. Outdoor Clothing Manufacturing Corporation (OCMC), Syfu,

President, Demogena, Finance Manager, and Paul Lee, Chairman January 21, 2010

Court concludes that Peñaflor did submit his resignation on March 15, 2000 on the following grounds:

1. Syfu’s memorandum of March 01, 2000 does not constitute conclusive evidence of their dates of preparation and communication.

2. Buenaobra’s acknowledgement and acceptance were only presented to the NLRC on appeal, not before the Labor Arbiter

3. Circumstances and evidences supports Peñaflor’s claim that he was compelled to resign from the company

Peñaflor would have become a regular employee by March 01, 2000. Court finds it unlikely that he would resign and would simply leave given his undisputed record of having successfully worked in the company and that he would tender his resignation on the very same day he was entitled by law to be considered a regular employee where he could have availed of its benefits if he would be separated from the service of a regular employee. Court finds it strange that Peñaflor would submit his resignation on March 01, 2000 and keep completely quiet about his development until its defective on March 15, 2000. In employee termination disputes, the employer bears the burden of proving that employees’ dismissal was for just and valid cause. Evidence does not support the existence of voluntariness in Peñaflor’s resignation. The principle that all doubts in the interpretation and implementation of the Labor Code should be interpreted in favor of the workingman has been extended by jurisprudence to cover the doubts in the evidence presented by the employer and employee. Ponente: Justice Brion FACTS: Peñaflor was hired on September 1999 as probationary Human Resources Department (HRD) Manager of respondent OCMC. His relationship with the company went well during the first few months wherein he designed and created the company’s Policy Manual, Personnel Handbook, Job Expectations and Organizational Set-Up during this period. His woes began when the company’s Vice President for Operations, Edgar Lee, left the company after a big fight between him and Chief Corporate Officer Syfu. Since he was in close association with Lee, he claimed that he was among those who bore Syfu’s ire. Peñaflor alleged that when the company’s downsizing program due to negative business returns began, his department had been singled out. His two staff members were dismissed in which he became a one-man department for the company – carrying out all clerical, administrative and liaison work.

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When employee Padilla suffered incident in a bombing incident, the company required him to attend to her hospitalizations needs; he had to work outside the office premises to undertake this task. When he considered himself to be on official business, he was surprised to discover that the company deducted six days’ salary corresponding to the time he assisted Padilla. Finance Manager Demogena explained that Peñaflor failed to submit his trip ticket which the latter belied as a trip ticket was required only when a company vehicle was used and he did not use any company vehicle when attended to his off-premises work. On March 13, 2000, Peñaflor learned that while he was away, Syfu appointed Buenaobra as the new HRD Manager. This was confirmed by Syfu’s memorandum of 2010 to the entire office stating that Buenaobra was the concurrent HRD and Accounting Manager. Surprised by the news, he tried to talk to Syfu to clarify the matter but he was unable to do so. Under these circumstances, Peñaflor allege that he had no option but to resign. He submitted a letter to Syfu declaring his irrevocable resignation from his employment on March 15, 2000. Then, Peñaflor filed a complaint for illegal dismissal with the labor arbiter on the grounds that he had been constructively dismissed. He included a prayer for reinstatement and payment of backwages, illegally deducted salaries, damages, attorney’s fees and other monetary claims. OCMC claimed that Peñaflor had voluntarily resigned from his work and that he had in fact continued working for the company until his resignation on March 15, 2000 – the company presented as evidence the security report Peñaflor prepared and signed on March 13, 2000. OCMC disclaimed liability for any of Penaflor’s monetary claims since the latter had voluntarily resigned he was not entitled to any backwages and damages. Company denied making illegal deduction from Peñaflor’s salary since these were deducted due to the latter’s failure to report for work during the dates the company questioned. Labor Arbiter found that Peñaflor had been illegally dismissed and ordered OCMC to reinstate the latter to his former position, to pay him his illegally deducted salary for six days, 13th month pay, attorney’s fees, moral and exemplary damages. OCMC appealed the decision to NLRC. The former insisted

1. Peñaflor had not been constructively dismissed 2. He tendered his resignation on March 01, 2000 because he saw no future with the corporation

due to its dire financial standing 3. Syfu allege that he was compelled to appoint Buenaobra through a memorandum dated March

01, 2000 to cover the position that Peñaflor would soon vacate and that the same was also made to address the matter that had to be taken care of while Peñaflor was on unauthorized leave.

4. They had given Peñaflor two notices on March 06 and March 11, 2000 for his unauthorized absences.

Peñaflor countered:

1. The March 01, 2000 memorandum, Buenaobra’s March 03, 2000 memorandum and the AWOL memoranda were fabricated and were never presented before the labor arbiter.

2. He rebutted Syfu’s claim that he submitted his letter on March 01, 2000 but was instead submitted on March 15, 2000.

3. AWOL memoranda could not be relied on since he was never furnished copies of these.

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4. He could not be on prolonged absence without official leave, as his residence was just a few meters away from his office.

NLRC overturned labor arbiter’s decision on the following grounds:

1. It characterized Peñaflor’s resignation to OCMC’s downward financial spiral. 2. No malice was present in the company’s decision to dismiss Peñaflor’s two staff members.

Peñaflor, in fact, drafted that dismissal of his staff members. Peñaflor filed a petition for certiorari with CA on the ground that NLRC’s decision was tainted with grave abuse of discretion, although he essentially adopted the same arguments he presented before the Labor Arbiter and the NLRC. CA affirmed NLRC’s decision stating that Peñaflor failed to present sufficient evidence supporting his claim that he had been constructively dismissed and subsequently denied Peñaflor’s motion for reconsideration; hence, this instant petition. ISSUE/S: Peñaflor’s Arguments: He had been constructively dismissed and that:

1. Dismissal of his two staff members 2. Demeaning liaison work he had to perform as HRD Manager 3. Salary deduction for his alleged unauthorized absences 4. Appointment of Buenaobra

were clear acts of discrimination which made his employment unbearable and thus, he was forced to resign. OCMC’s Arguments: Peñaflor voluntarily resigned, his allegations were all unsubstantiated and that:

1. HRD was not singled out but was the first to lose its staff members because the company had to downsize.

2. Peñaflor unreasonably felt humiliated in performing work that logically fell under his department.

3. Absented himself from work without official leave; and 4. Demanded payment for his unauthorized absences.

Main Issue: Whether Peñaflor’s undisputed resignations was voluntary or a forced one - constructive dismissal equivalent to an illegal dismissal. Critical Issue: Whether Peñaflor filed his letter of resignation before or after the appointment of Buenaobra as the new/concurrent HRD manager DECISION: The court granted Peñaflor’s petition, reversed NLRC and CA’s decision and resolution, reinstated Labor Arbiter’s decision with modification that due to the strained relations between the parties, respondents are additionally ordered to pay separation pay equivalent to the petitioner’s one month’s salary.

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Court concludes that Peñaflor did submit his resignation on March 15, 2000 on the following grounds: 1. Syfu’s memorandum of March 01, 2000 does not constitute conclusive evidence of their dates

of preparation and communication. 2. Buenaobra’s acknowledgement and acceptance were only presented to the NLRC on appeal,

not before the Labor Arbiter - OCMC totally failed to explain the reason for its omission. This is significant since these were the clinching pieces of evidence that allowed NLRC to justify the reversal of the Labor Arbiter’s decision.

3. Circumstances and evidences supports Peñaflor’s claim that he was compelled to resign from the company – Three of the company’s officials acknowledged receipt on March 13, 2000 of the March 10 Memorandum showing that indeed it was only that day that the appointment of Buenaobra to the HRD position was disclosed. This was consistent in Peñaflor’s position that it was only in the afternoon of March 13, 2000 that he was told, informally, that Buenaobra had taken over his position.

Peñaflor would have become a regular employee by March 01, 2000. Court finds it unlikely that he would resign and would simply leave given his undisputed record of having successfully worked in the company and that he would tender his resignation on the very same day he was entitled by law to be considered a regular employee where he could have availed of its benefits if he would be separated from the service of a regular employee. Court finds it strange that Peñaflor would submit his resignation on March 01, 2000 and keep completely quiet about his development until its defective on March 15, 2000. It is more consistent with human experience that Peñaflor indeed learned of the appointment of Buenaobra only on March 13, 2000 and reacted to this development through his resignation letter after realizing that he would only face hostility and frustration in his working environment. In employee termination disputes, the employer bears the burden of proving that employees’ dismissal was for just and valid cause. Evidence does not support the existence of voluntariness in Peñaflor’s resignation. Peñaflor’s letter of resignation does not help the company’s case since the company must still prove that the employee voluntarily resigned. There can be no valid resignation where the acts was made under the compulsion or under circumstances approximating compulsion, such as when an employee’s act of handing in his resignation was a reaction to circumstances leaving him no alternative but to resign. The principle that all doubts in the interpretation and implementation of the Labor Code should be interpreted in favor of the workingman has been extended by jurisprudence to cover the doubts in the evidence presented by the employer and employee. Peñaflor has shown serious doubts about the merits of the company’s case, particularly in the appreciation of the clinching evidence on which NLRC and CA decision were based. Article 4 compels the court to rule in Peñaflor’s favor.

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GR No. 165153 De Castro vs. Liberty Broadcasting Network, Inc. and Quiogue, respondents

September 23, 2008 CA erred in appreciation of evidence surrounding De Castro’s termination from employment. The cited grounds are doubtful under proven circumstances and should have been interpreted in De Castro’s favor pursuant to Article 4 of the Labor Code.

1. Petitioner had not even passed his probationary period when the acts charged allegedly took place.

2. De Castro’s relationships within the company at the time the charges were filed showed that he might have stepped in the wrong toes in the course of performing his duties.

3. The timing of the filling of the charges was unusual If doubts exist between the evidence presented by the employer and the employee, the scales of justice must be tilted in favor of the latter – it is a time-honored rule in controversies between a laborer and his master, doubts reasonably arising from the evidence or in the interpretation of agreements and writing should be resolved in the former’s favor. Employer failed to prove a just cause for the termination of the petitioner’s employment and CA erred when it saw grave abuse of discretion in NLRC’s ruling. Ponente: Justice Brion FACTS: August 1995, De Castro commenced his employment as Building Administrator for respondent company. May 1996, respondent company through HRM Senior Manager Mandap sent notice to petitioner requiring him to explain with 48 hours why he should not be made liable for violation of Company Code of Conduct for acts constituting serious misconduct, fraud and wilful breach of the trust reposed on him. Petitioner denied the allegations made by Niguidula and Balais and labeled as completely baseless and sham, designed to protect them as they were favorites of Quiogue. The company granted petitioner’s request for a formal hearing, however, petitioner sent notice that he would not participate when he learned from his wife that criminal cases for estafa and qualified theft had been filed against him in the Prosecutor’s office. He felt that the said hearing would be a “Moro-Moro” investigation. May 24, 1996, the company further charged De Castro for violation of the Company Code of Conduct based on affidavits of Balais, Samarita and Aying. May 31, 1996, the company dismissed De Castro on the following grounds:

1. Soliciting money for his own benefit from suppliers Aying and Samarita. 2. Soliciting P14 000 in commission from Aying. 3. Theft of company property for unauthorized removal of one gallon of Delo Oil from the storage

room.

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4. Discourtesy towards a co-employee for offensive language against Niguidula. 5. Disorderly behavior for challenging Niguidula for a fight, thereby creating a disturbance in the

normal flow of activities in the company. 6. Threat and Coercion for threatening bodily harm to Niguidula and coercing Balais to solicit

money in his behalf. 7. Abuse of authority for instructing Balais to collect commission from Aying and Samarita. 8. Slander for uttering libelous statement against Niguidula.

De Castro filed a complaint for illegal dismissal in the NLRC. Labor Arbiter Pati: De Castro’s favor, disbelieved the affidavits submitted by Niguidula, Balais, Pacaldo, Samarita and Aying. NLRC: Reversed Labor Arbiter’s decision, Labor Arbiter erred in disregarding the affidavits of respondents’ witness. NLRC adopted Labor Arbiter Tamayo’s findings. NLRC Motion for Reconsideration: De Castro’s favor, charges against petitioner were never really substantiated other than bare allegations in the affidavits of witnesses who were company’s employees and who had altercations with petitioner prior to execution of their affidavits. CA: Company’s favor, NLRC committed grave abuse of discretion in disregarding the affidavits of all respondent’s witnesses. CA denied De Castro’s motion for reconsideration; hence, this instant petition. ISSUE/S: De Castro’s Arguments:

1. CA erred when it substituted its judgment for that of the Labor Arbiter and NLRC who were “trier of facts” who had the opportunity to review the evidence extensively.

2. His termination was a hatchet job maliciously concocted by Quiogue. He questions the charge that he conspired with his fellow managers in December 1995 and asks why the investigation and supporting evidence came only in 1996.

3. Aying’s change of statement proves that the charges against him have been concocted. 4. He belies that he slandered and challenged Niguidula to fight; in fact, it was Niguidula who

defamed him. He even complained in writing to Quiogue about the incident immediately after it happened and furnished copies to company officials.

5. Quiogue failed to act on his complaint against Niguidula only to resurrect it under the Notice of Violation served on him. This time, however, Niguidula was already the victim.

6. In the notice of violation, although he was given 48 hours to explain, Quiogue, in bad faith, immediately filed complaints for estafa and qualified theft against him. Mandap even went to his residence and warned his wife not to file charges against the company, or else, Quiogue would file cases against him in regular courts.

Respondent Company’s Arguments:

1. CA correctly ruled that NLRC committed grave abuse of discretion. Positive Testimonies of the witnesses should be given credence.

2. Petitioner failed to rebut Samarita’s testimony that he was forced to increase the price for the construction of the fire exits because De Castro asked for commissions.

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3. De Castro’s claim that Quiogue orchestrated his dismissal is not supported by evidence and that the gravity of the charges faced by De Castro are just causes for termination of employment under the Labor Code.

W/N De Castro was illegally dismissed. DECISION: The court granted De Castro’s petition by reversing CA’s decision and reinstating NLRC’s decision. CA erred in appreciation of evidence surrounding De Castro’s termination from employment. The cited grounds are doubtful under proven circumstances and should have been interpreted in De Castro’s favor pursuant to Article 4 of the Labor Code.

4. Petitioner had not even passed his probationary period when the acts charged allegedly took place. This provides the following implications:

a. As a new employee, his natural motivation was to make an early positive impression on his employer.

b. His natural motivation as new employee and lack of awareness of the dynamics of relationships within the company supports his action of objecting to the way the contract for the installation of the fire escapes was awarded to Samarita.

c. As a new employee, it is doubtful that he had already encouraged solicitation of commission from suppliers. This was supported by the turnaround of Aying’s testimony.

5. De Castro’s relationships within the company at the time the charges were filed showed that he might have stepped in the wrong toes in the course of performing his duties.

a. Samarita – had hidden dynamics with Quiogue since he was doing the steel balusters for Quiogue’s home.

b. Mandap – Quiogue’s subordinate. c. Niguidula, purchasing manager, - is one who might be expected to be in charge of

actions regarding supply deals. He would not welcome a zealous building administrator who can see how supplies are procured and used.

d. Pacaldo – subordinate of Niguidula e. Balais – air-con maintenance whom De Castro reprimanded for unauthorized overtime

work on an air-conditioning unit.

6. The timing of the filling of the charges was unusual – the proposal to solicit commission transpired in December, the charges were late when they came in May. Also:

a. It was in April 1996 when De Castro questioned Quiogue’s decision to award the contract to Samarita.

b. De Castro reprimanded Balais on the first week of May, an incident he reported to Quiogue.

c. On May 09, 1996, De Castro had an altercation with Niguidula, an incident he reported to Quigoue.

If doubts exist between the evidence presented by the employer and the employee, the scales of justice must be tilted in favor of the latter – it is a time-honored rule in controversies between a laborer and his master, doubts reasonably arising from the evidence or in the interpretation of agreements and writing should be resolved in the former’s favor.

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Employer failed to prove a just cause for the termination of the petitioner’s employment and CA erred when it saw grave abuse of discretion in NLRC’s ruling.

LABOR STANDARDS TOPIC: Social Justice

GR No. 157098 Norkis Free and Independent Worker Union (NFIWU) vs. Norkis Trading

Company (NTC), Inc June 30, 2005

Stipulations in a contract must be read together not in isolation from one another. The terms and clauses are clear and leave no room for doubt as to the intention of the contracting parties whose literal meanings should prevail. The wage order was intended to fix a new minimum wage only, not to grant across –the-board wage increases. A reading of the wage order convinces the court that the intention of RTWPB was to prescribe a “floor wage”; not a “salary ceiling” This was affirmed in a letter-opinion sent by RTPWB in answering the respondent company’s queries. RTPWB was only interpreting its own issuance, not a statutory provision. The best authority to construe a rule or an issuance is its very source, RTPWB. Social justice does not mandate that every dispute should be automatically decided in favor of labor. Court has always been guided by the State policy enshrined in the Constitution: social justice and the protection of the working class. Social justice does not, however, mandate that every dispute should be automatically decided in favor of labor. In every case, justice is to be granted to the deserving and dispensed in the light of the established facts and the applicable law and doctrine. Ponente: Justice Panganiban FACTS: Petitioner NFIWU and respondent company NTC entered into a Collective Bargaining Agreement (CBA). Section 2 Article XII of the same states: “In the event a law is enacted increasing the minimum wage, an across-the-board increase shall be granted by the company according to the provisions of law.” On March 1998, Regional Tripartite Wage Productivity Board (RTWPB) of Region VII issued Wage Order ROVII-06 establishing the minimum wage of P165.00 by mandating an increase of P5.00 beginning April 1998 and another P5.00 effective October 01, 1998. Prior to this order, NFIWU and NTC had a memorandum of agreement stating providing: “P10.00 increase effective August 01, 1997 and another P10.00 increase effective August 01, 1998.” Thus, by the time the minimum wage was set by law at P165.00, NTC pays their employees at a minimum wage of P175.00

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In accordance with the Wage Order, NFIWU demand an across-the-board increase. NTC, however, refused to implement the Wage Order arguing that long before the passage of the said order, they have been paying its employees a daily wage of P165.00 while the minimum wage at that time was still P155.00 per day. When the Order became effective prescribing the new minimum wage of P165.00 per day, the employees were already receiving P175.00 per day. For failure to settle this controversy, a complaint was filed by petitioner in the National Conciliation and Mediation Board where both parties selected an arbitrator to decide the controversy. Arbitrator: NFIWU’s favor, NTC failed to comply with contractual obligation, particularly, in Section 2 of Article XII of the CBA. CA: NTC’s favor, CA considered RTWPB’s opinion in the scope and application of the wage order where it showed that NTC sufficiently complied with the said wage order. The wage order exempted enterprises already paying salary equal to or more than the prescribed minimum wage; thus, the order effectively made the previous voluntary increases given by respondent to its employees creditable against the law-mandated increase. Hence, this instant petition ISSUE/S: W/N NTC violated the CBA in its refusal to grant its employees an across-the-board increase as a result of the passage of Wage Order No. ROVII-06. DECISION: The court denied this petition and affirmed CA’s decision. Stipulations in a contract must be read together not in isolation from one another. The terms and clauses are clear and leave no room for doubt as to the intention of the contracting parties whose literal meanings should prevail. Collective Bargaining Agreement (CBA) Section 2 Article XII of the same states: “In the event a law is enacted increasing the minimum wage, an across-the-board increase shall be granted by the company according to the provisions of law.” Petitioner disregards in its argument the qualifying phrase “according to the provisions of the law.” Stipulations in a contract must be read together not in isolation from one another. The terms and clauses are clear and leave no room for doubt as to the intention of the contracting parties whose literal meanings should prevail. The wage order was intended to fix a new minimum wage only, not to grant across –the-board wage increases. In Employers Confederation of the Phils. Vs. National Wages and Productivity Commission, the court held that there are two methods of adjusting the minimum wage:

1. Floor Wage – fixing of determinate amount to be added to the prevailing statutory minimum wage rates.

2. Salary Ceiling – workers already paid more than the existing minimum wage are also to be given a wage increase.

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A reading of the wage order convinces the court that the intention of RTWPB was to prescribe a “floor wage”; not a “salary ceiling” This was affirmed in a letter-opinion sent by RTPWB in answering the respondent company’s queries. RTPWB was only interpreting its own issuance, not a statutory provision. The best authority to construe a rule or an issuance is its very source, RTPWB. The board has the authority to interpret its own rules and issuances; any phrase contained in its interpretation becomes a part of those rules or issuances themselves. Thus, it was proper for CA to consider the letter-opinion written by RTWPB to explain the scope and import of its own order; as such interpretation is deemed part of the order itself. Social justice does not mandate that every dispute should be automatically decided in favor of labor. Court has always been guided by the State policy enshrined in the Constitution: social justice and the protection of the working class. Social justice does not, however, mandate that every dispute should be automatically decided in favor of labor. In every case, justice is to be granted to the deserving and dispensed in the light of the established facts and the applicable law and doctrine.