Flores v. NLRC

G.R. No. 109362 (May 15, 1996)

Celia A. Flores was dismissed for misconduct; NLRC upheld her termination despite union-related claims.

Facts:

Petitioner Celia A. Flores was employed as a casual employee by the Philippine Public School Teachers Association (PPSTA) in 1973 and became a regular employee on August 6, 1976. On September 3, 1990, she was dismissed from her position following a recommendation from an investigating committee after an incident on February 20, 1990, where she engaged in a physical altercation with a fellow employee, Lamberto Jamlang, in the PPSTA Administration Building. This incident occurred in the presence of other employees and visitors.

The PPSTA cited Flores' history of misconduct as a basis for her dismissal, detailing multiple instances of tardiness, absenteeism, insubordination, and previous disciplinary actions, including a 15-day suspension in 1977 and a prior dismissal in 1986 for serious misconduct. Although she was temporarily reinstated after the 1986 dismissal due to a compromise agreement during a strike, the PPSTA maintained that her continued employment was detrimental to the organization.

In response to her dismissal, Flores filed a complaint for illegal dismissal, arguing that the altercation was not a valid ground for termination as there was no evidence she initiated the fight. She also contended that her past misconduct could not be used against her since she had not been formally informed of the charges or given a chance to respond. Furthermore, she alleged that her dismissal was motivated by her union activities, having served as the union president from 1985 until her termination.

The Labor Arbiter ruled in favor of Flores, declaring her dismissal illegal but dismissing her claim of unfair labor practice. The PPSTA appealed this decision to the National Labor Relations Commission (NLRC), which reversed the Labor Arbiter's ruling, declaring the dismissal valid but awarding Flores separation pay equivalent to one-half month’s salary for each year of service.

Flores subsequently filed a motion for reconsideration, which was denied by the NLRC on the grounds that it was filed beyond the reglementary period. This led to her petition for certiorari to annul the NLRC's decision and resolution.

Legal Issues:

  1. Was the dismissal of Celia A. Flores valid and justified based on the grounds cited by the PPSTA?
  2. Did the NLRC err in its decision to award separation pay to Flores despite the finding of valid grounds for her dismissal?
  3. Was Flores' motion for reconsideration filed within the reglementary period?

Arguments:

  • Petitioner (Flores):

    • Argued that the altercation with Jamlang was not initiated by her and thus should not be grounds for dismissal.
    • Contended that her past misconduct could not be used against her as she was not properly informed of the charges or given an opportunity to respond.
    • Claimed that her dismissal was a result of her union activities and not due to her conduct.

  • Respondent (PPSTA):

    • Maintained that Flores' history of misconduct and the February 20 incident justified her dismissal.
    • Asserted that her continued employment was detrimental to the organization, citing her repeated violations of company rules and regulations.
    • Argued that the NLRC's award of separation pay was unwarranted given the circumstances of her dismissal.

Court's Decision and Legal Reasoning:

The Supreme Court dismissed Flores' petition for certiorari, finding no merit in her claims. The Court upheld the NLRC's decision, affirming that the dismissal was valid based on the evidence of Flores' misconduct, including her involvement in the fight and her history of violations. The Court noted that fighting within the workplace is a valid ground for dismissal, regardless of who initiated the altercation.

The Court also addressed the issue of the motion for reconsideration, stating that Flores' counsel failed to file it within the ten-day period required by the NLRC Rules of Procedure. The presumption of regularity in the delivery of the NLRC's decision was not overcome by Flores, leading to the conclusion that the NLRC's decision became final and executory.

Regarding the separation pay, the Court indicated that since the PPSTA did not contest this aspect of the NLRC's ruling, it could not be reviewed. The Court emphasized that while the law protects labor rights, it does not permit the oppression or self-destruction of the employer.

Significant Legal Principles Established:

  1. Grounds for Dismissal: Engaging in a physical altercation within the workplace is a valid ground for dismissal, irrespective of who initiated the fight.
  2. Presumption of Regularity: There is a presumption that official duties, such as the delivery of decisions, are performed regularly unless proven otherwise.
  3. Finality of Decisions: A motion for reconsideration must be filed within the prescribed period; failure to do so results in the decision becoming final and executory.