Quiambao v. NLRC

G.R. No. 91935 (March 4, 1996)

Supreme Court reinstated Rodolfo Quiambao, invalidating NLRC ruling for lack of supersedeas bond.

Facts:

Rodolfo Quiambao was employed as the officer-in-charge of Central Cement Corporation's Tuguegarao Branch on December 1, 1982, and was later promoted to Branch Manager. His compensation included a monthly salary of P2,500.00, an emergency cost of living allowance of P350.00, and a representation allowance of P200.00. Quiambao was responsible for credit collections and was required to submit monthly operational reports to the Central Office.

In April 1984, a financial and performance audit revealed significant issues at the Tuguegarao Branch. Subsequently, on May 25, 1984, Quiambao was suspended indefinitely due to alleged poor performance, violation of company rules, and gross negligence. An investigation led to criminal charges of estafa against him, which were initially dismissed but later reinstated by the Ministry of Justice. However, the case was ultimately dismissed by the Regional Trial Court due to the prosecution's failure to present witnesses. A civil suit for collection against Quiambao was also dismissed for lack of evidence.

On March 15, 1985, Quiambao demanded reinstatement with back wages, but Central Cement instead issued a notice of termination citing loss of confidence. Quiambao then filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, declaring the dismissal illegal and awarding him back wages, separation pay, and moral damages.

Central Cement appealed the decision to the National Labor Relations Commission (NLRC), which did not act on Quiambao's motion to dismiss the appeal for lack of a supersedeas bond. The NLRC ultimately reversed the Labor Arbiter's decision, leading Quiambao to file a petition for certiorari, alleging grave abuse of discretion by the NLRC.

Legal Issues:

  1. Did the NLRC commit grave abuse of discretion by disregarding the requirement for a supersedeas bond for the perfection of an appeal?
  2. Was the dismissal of Quiambao justified based on the allegations of loss of confidence?
  3. Did the NLRC properly consider the merits of the case in its decision?

Arguments:

Petitioner (Quiambao):

  • Argued that the NLRC acted without jurisdiction because Central Cement failed to post a supersedeas bond, rendering the Labor Arbiter's decision final and executory.
  • Contended that the NLRC disregarded established facts and evidence, particularly regarding the lack of due process in his dismissal.
  • Asserted that the NLRC's finding of just cause for dismissal was unsupported by evidence, as the criminal charges against him were dismissed.

Respondent (Central Cement):

  • Claimed that the requirement for a supersedeas bond was not applicable at the time of their appeal, arguing that Article 223 of the Labor Code was not self-executing.
  • Maintained that the dismissal was justified due to the loss of trust and confidence stemming from the criminal charges filed against Quiambao.

Court's Decision and Legal Reasoning:

The Supreme Court granted Quiambao's petition, setting aside the NLRC's decision and reinstating the Labor Arbiter's ruling. The Court held that:

  1. The filing of a supersedeas bond is mandatory for the perfection of an appeal involving monetary awards, as stipulated in Article 223 of the Labor Code. Central Cement's failure to post the bond rendered the Labor Arbiter's decision final and executory, thus the NLRC acted without jurisdiction in reversing it.

  2. The NLRC's justification for Quiambao's dismissal based on loss of confidence was unfounded. The Court noted that the NLRC itself found Central Cement failed to substantiate its allegations against Quiambao. The mere filing of criminal charges, which were ultimately dismissed, could not justify the loss of trust without a proper investigation or evidence of wrongdoing.

  3. The Court emphasized that the absence of an investigation by Central Cement into the allegations against Quiambao further undermined the validity of the dismissal. The lack of evidence supporting the claims of misconduct rendered the dismissal arbitrary and unjust.

Significant Legal Principles Established:

  • The requirement for a supersedeas bond in labor cases involving monetary awards is mandatory and jurisdictional, and failure to comply renders the Labor Arbiter's decision final and executory.
  • An employer's claim of loss of confidence must be substantiated by evidence and due process; mere allegations or unproven criminal charges are insufficient grounds for dismissal.
  • The right to security of tenure is a fundamental principle in labor law, and dismissals must be based on just and valid causes supported by evidence.