Wuerth Phils. v. Ynson

G.R. No. 175932 (February 15, 2012)

Supreme Court upheld Ynson's dismissal for prolonged absences, affirming employer's rights.

Facts:

On August 15, 2001, Wuerth Philippines, Inc. hired Rodante Ynson as its National Sales Manager (NSM) for Automotive. Ynson's responsibilities included supervising sales activities across the country, creating sales schedules, and reporting to the Chief Executive Officer, Marlon Ricanor. On January 4, 2003, Ynson communicated his sales targets and planned leave from January 23 to 24, 2003. However, he suffered a stroke on January 24, 2003, and was hospitalized until February 3, 2003. He informed his employer about his condition.

Medical certificates from Dr. Daniel de la Paz indicated that Ynson was under care for his stroke and advised continued rehabilitation. On June 4, 2003, Dr. de la Paz cleared Ynson to return to work but recommended ongoing rehabilitation. Despite this, Ynson requested to work from Davao City due to his rehabilitation needs, which was denied by the company.

Ricanor subsequently sent Ynson letters requiring him to attend an investigation regarding his absences, which he failed to attend, citing his medical condition. On August 27, 2003, Wuerth Philippines terminated Ynson's employment, citing continued absences without leave and abandonment of work.

Ynson filed a complaint for illegal dismissal and non-payment of allowances with the National Labor Relations Commission (NLRC). The Labor Arbiter ruled in favor of Ynson, finding illegal dismissal and ordering reinstatement and monetary awards. The NLRC modified the decision, reducing the damages awarded. Wuerth Philippines then appealed to the Court of Appeals (CA), which found that the company had the right to terminate Ynson's employment but modified the monetary awards.

Legal Issues:

  1. Was the termination of Rodante Ynson's employment valid under the Labor Code?
  2. Did Wuerth Philippines comply with the procedural requirements for terminating an employee due to illness?
  3. What monetary awards, if any, should Ynson be entitled to following the termination?

Arguments:

  • Petitioner (Wuerth Philippines, Inc.):

    • Argued that Ynson's prolonged absence constituted gross dereliction of duty and abandonment of work.
    • Claimed that Ynson's illness did not prevent him from attending the investigation or returning to work after being cleared by his doctors.
    • Contended that the CA erred in awarding backwages, medical expenses, temperate damages, and attorney's fees.

  • Respondent (Rodante Ynson):

    • Asserted that his absence was due to a legitimate medical condition and that he had informed the company of his situation.
    • Argued that the company failed to comply with the requirement of obtaining a medical certificate before termination, as mandated by the Labor Code.
    • Claimed entitlement to backwages, medical expenses, and damages due to illegal dismissal.

Court's Decision and Legal Reasoning:

The Supreme Court ruled that Wuerth Philippines had the right to terminate Ynson's employment but noted that the company did not comply with the procedural requirements set forth in the Labor Code regarding termination due to illness. Specifically, the Court highlighted that there was no certification from a competent public health authority confirming that Ynson's illness was of such a nature that it could not be cured within six months.

The Court found that while Ynson's illness justified a leave of absence, his failure to report to work or attend the investigations after being cleared by his doctors constituted a waiver of his right to contest the termination. The Court emphasized that managerial employees are held to a higher standard of responsibility and that Ynson's prolonged absence without valid justification was detrimental to the company's operations.

Regarding monetary awards, the Court modified the CA's decision by:

  • Deleting the award of backwages from February 2003 to August 29, 2003, and instead allowing Ynson to receive salary for the period he was incapacitated (January 24 to June 4, 2003) chargeable against his sick leave benefits.
  • Reducing the temperate damages from P100,000.00 to P50,000.00.
  • Deleting the award for medical expenses due to lack of proof.
  • Clarifying that while Ynson was not entitled to 13th month pay under the law, he may still be entitled to it based on company policy.
  • Denying attorney's fees due to the absence of bad faith in the dismissal.

Significant Legal Principles Established:

  1. Termination Due to Illness: Employers must comply with the procedural requirements of obtaining a medical certificate before terminating an employee due to illness, as outlined in Article 284 of the Labor Code and its implementing rules.
  2. Managerial Responsibility: Managerial employees are held to a higher standard of accountability, and their prolonged absence without valid justification can lead to termination.
  3. Monetary Awards: Employees are entitled to compensation only for the actual work performed, and claims for damages must be substantiated with competent evidence.