Stellar Industrial Services v. NLRC

G.R. No. 117418 (January 24, 1996)

Facts:

Stellar Industrial Services, Inc. (Stellar) is an independent contractor providing manpower services. It employed Roberto H. Pepito as a janitor on January 27, 1975, assigning him to work at the Maintenance Base Complex of the Philippine Airlines (MBC-PAL) in Pasay City. Over his 15 years of service, Pepito was noted for various infractions, including tardiness and gambling, but Stellar retained him out of humanitarian considerations.

On January 22, 1991, Stellar terminated Pepito's employment, citing his absence without official leave (AWOL) from November 2 to December 10, 1990. Pepito contended that he was unable to work due to severe stomach pain, supported by a medical certificate. Following his dismissal, Pepito filed a complaint with the National Labor Relations Commission (NLRC) for illegal dismissal, illegal deductions, and underpayment of wages.

The labor arbiter ruled in favor of Pepito, declaring his dismissal illegal and ordering his reinstatement with back wages. The NLRC affirmed this decision, leading Stellar to seek a certiorari from the Supreme Court, alleging grave abuse of discretion by the NLRC.

Legal Issues:

1. Whether the NLRC committed grave abuse of discretion in affirming the labor arbiter's decision regarding Pepito's dismissal.
2. Whether Pepito's absence constituted abandonment of work or was justified due to illness.
3. Whether the deductions from Pepito's salary were lawful.

Arguments:

• Petitioner (Stellar):

  • Stellar argued that the NLRC improperly addressed the issue of abandonment, which was not raised in the initial proceedings.
  • It contended that Pepito's medical certificate did not sufficiently justify his absences and that his past infractions warranted his dismissal.
  • Stellar claimed that the deductions from Pepito's salary were authorized by a board resolution of the Stellar Employees Association.

• Respondent (Pepito):

  • Pepito maintained that his absences were due to legitimate illness, as evidenced by the medical certificate.
  • He argued that he complied with company rules regarding notification of absences and that his dismissal lacked just cause.
  • Pepito contended that the deductions from his salary were unauthorized and illegal under the Labor Code.

Court's Decision and Legal Reasoning:

The Supreme Court dismissed Stellar's petition, finding no grave abuse of discretion by the NLRC. The Court noted that the issue of abandonment was not a valid ground for dismissal since Stellar had not raised it as a reason for termination. Instead, the dismissal was based on Pepito's alleged failure to file an official leave of absence.

The Court emphasized that Pepito had substantially complied with company rules by notifying his supervisor of his illness. The medical certificate provided by Pepito was deemed credible, confirming that he was indeed incapacitated during the period of his absence. The Court rejected Stellar's interpretation of the medical certificate, affirming that it clearly indicated Pepito's inability to work due to actual illness.

Furthermore, the Court ruled that previous infractions could not be used to justify dismissal for a different offense, especially since Pepito's absences were justified. The deductions from Pepito's salary were also found to be unlawful, as they were not authorized by a majority of the labor organization members.

Significant Legal Principles Established:

1. Just Cause for Dismissal: An employee's dismissal must be based on just cause, and previous infractions can only be considered if they are similar to the current offense.
2. Compliance with Company Rules: Employees must be given fair consideration for compliance with notification procedures regarding absences due to illness.
3. Salary Deductions: Any deductions from an employee's salary must be authorized by a majority of the labor organization members and cannot be based solely on a board resolution.