Functional, Inc. v. Granfil
G.R. No. 176377 (November 16, 2011)
Facts:
Respondent Samuel C. Granfil was employed by petitioner Functional, Inc. (FI) as a key operator since 1992, primarily responsible for operating a photocopying machine rented by the National Bookstore (NBS) at its SM Megamall Branch. On the evening of July 30, 2002, Granfil attended to a customer, Cosme Cavaldeja, who requested photocopying services. After the transaction, a security guard, Bonnel Dechavez, observed Cavaldeja handing money to Granfil. Following this incident, Dechavez reported the matter to NBS Branch Manager Lucy Genegaban, indicating that Cavaldeja had not paid at the cashier's counter.
On September 3, 2002, Granfil filed a complaint against FI and several of its officers for illegal dismissal, unpaid 13th month pay, and damages. He contended that the money he received from Cavaldeja was a tip for his assistance, and that the payment for the photocopying had already been settled by Cavaldeja's wife. Granfil alleged that instead of allowing him to explain, he was ordered to resign by Tenorio, the Marketing Manager, and was subsequently terminated without due process.
In response, FI claimed that Granfil was not dismissed but rather transferred to a different assignment due to the incident. They argued that Granfil's refusal to report to the main office constituted abandonment of his employment. The Labor Arbiter ruled in favor of FI, stating that Granfil had not proven his illegal dismissal. Granfil appealed to the National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's decision.
Granfil then elevated the case to the Court of Appeals (CA) through a petition for certiorari, which ultimately reversed the NLRC's decision, ordering his reinstatement and the payment of back wages.
Legal Issues:
- Was Granfil illegally dismissed from his employment?
- Did FI provide sufficient evidence to support its claim of abandonment of employment by Granfil?
- Should the findings of the Labor Arbiter and the NLRC be given credence over the CA's ruling?
Arguments:
Petitioner (FI):
- Granfil was not dismissed but was merely transferred to a different assignment, which he misconstrued as a punishment.
- Granfil abandoned his employment by refusing to report to the main office after the transfer.
- The Labor Arbiter and NLRC's findings should be upheld as they were based on substantial evidence.
Respondent (Granfil):
- He was illegally dismissed without just cause and due process.
- The money received from Cavaldeja was a tip, not a payment for services rendered, and he was not given a chance to explain.
- His filing of the complaint for illegal dismissal demonstrated his intention to continue his employment, negating any claim of abandonment.
Court's Decision and Legal Reasoning:
The Supreme Court denied FI's petition, affirming the CA's decision. The Court emphasized that the burden of proof lies with the employer to demonstrate that the termination was for a just cause. In this case, FI failed to provide substantial evidence to support its claim of Granfil's abandonment of employment. The Court noted that mere absence from work does not equate to abandonment, which requires a clear intention to sever the employer-employee relationship.
The Court also highlighted that the CA correctly ruled out FI's position on abandonment, as Granfil's actions, including filing a complaint for illegal dismissal, indicated his desire to return to work. The Court reiterated that administrative findings of fact are respected but can be overturned if there is a gross misapprehension of evidence.
Significant Legal Principles Established:
- The burden of proof in illegal dismissal cases rests on the employer to show just cause for termination.
- Abandonment of employment requires clear intent and overt acts indicating a refusal to return to work, which must be proven by the employer.
- Mere absence from work does not constitute abandonment; the employee's actions must reflect an intention to sever the employment relationship.