Bustamante v. NLRC
G.R. No. 111651 (November 28, 1996)
Facts:
The case involves a group of petitioners—Osmalik S. Bustamante, Paulino A. Bantayan, Fernando L. Bustamante, Mario D. Sumonod, and Sabu J. Lamarán—who were employed by Anda Evergreen Farms, Inc. The petitioners were dismissed from their positions on June 25, 1990, during their probationary period. They filed a complaint for illegal dismissal, which was initially decided in their favor by the Labor Arbiter, who ordered their reinstatement and awarded them backwages.
The National Labor Relations Commission (NLRC) later modified the Labor Arbiter's decision, deleting the award for backwages. The petitioners appealed this decision, and on March 15, 1996, the Supreme Court's First Division modified the NLRC's resolution, reinstating the award for backwages from the time of their illegal dismissal until their reinstatement or, if reinstatement was no longer feasible, a one-month salary as separation pay.
The private respondent, Anda Evergreen Farms, Inc., filed a motion for reconsideration, arguing that the petitioners were not entitled to backwages because they were not actually dismissed but rather their probationary employment was not converted to permanent status. They also contended that if backwages were to be awarded, the computation should not start from the cessation of work but should deduct any earnings the petitioners made from other employment during the period of their illegal dismissal.
Legal Issues:
- Whether the petitioners were illegally dismissed and entitled to backwages.
- The proper computation of backwages in light of the petitioners' earnings from other employment during the period of their dismissal.
- The implications of the amendments introduced by Republic Act No. 6715 on the award of backwages.
Arguments:
Petitioners' Argument: The petitioners argued that they were illegally dismissed and thus entitled to backwages from the time of their dismissal until their reinstatement. They contended that the law mandates full backwages without deductions for any earnings from other employment during the period of dismissal.
Respondent's Argument: Anda Evergreen Farms, Inc. contended that the petitioners were not dismissed but rather their probationary employment was not converted to permanent status. They further argued that if backwages were to be awarded, the computation should account for any earnings the petitioners received from other employment during the period of their dismissal, to avoid unjust enrichment.
Court's Decision and Legal Reasoning:
The Supreme Court denied the motion for reconsideration filed by Anda Evergreen Farms, Inc. The Court clarified the computation of backwages due to an employee who has been illegally dismissed. It emphasized that under Republic Act No. 6715, an illegally dismissed employee is entitled to full backwages from the time their compensation was withheld until their actual reinstatement, without deductions for earnings from other employment during the period of dismissal.
The Court reasoned that the legislative intent behind the amendment was to provide greater benefits to workers, and thus the term "full backwages" should be interpreted literally, meaning that no deductions should be made for earnings derived from other employment. The Court also noted that reinstatement was no longer feasible due to the age of the petitioners, and therefore, the separation pay equivalent to one month’s salary was appropriate.
Significant Legal Principles Established:
Full Backwages Entitlement: Under Republic Act No. 6715, illegally dismissed employees are entitled to full backwages from the time their compensation was withheld until their actual reinstatement, without deductions for earnings from other employment.
Legislative Intent: The amendments introduced by Republic Act No. 6715 reflect a clear legislative intent to enhance the protection and benefits afforded to workers, moving away from previous jurisprudential rules that allowed for deductions from backwages.
Separation Pay in Lieu of Reinstatement: In cases where reinstatement is no longer feasible, the award of separation pay is justified and should be equivalent to one month’s salary.