Stanley Fine Furniture, Elena Briones, and Carlos Wang vs. Victor T. Gallano and Enriquito Siarez, G.R. No. 748 Phil. 624 (2014)
**Facts:**
– **1995:** Victor Gallano and Enriquito Siarez were hired as painter/carpenters by Stanley Fine Furniture, owned by Elena and Carlos Wang, with a daily wage of PHP 215 each.
– **May 26, 2005:** Gallano and Siarez filed a labor complaint alleging underpayment/non-payment of salaries, wages, ECOLA, and 13th month pay, stating they were still employed.
– **May 31, 2005:** They amended their complaint to include actual illegal dismissal, non-payment of overtime, holiday, service incentive leave, and SSS benefits, claiming they were dismissed on May 26, 2005.
– **May 23, 2005 – June 1, 2005:** Petitioner Elena Briones issued memoranda to Gallano and Siarez asking them to explain their absences, which they allegedly refused to acknowledge.
– **August 2, 2006:** Labor Arbiter ruled in favor of Gallano and Siarez, finding their dismissal illegal and awarded them moral and exemplary damages. Stanley Fine was ordered to reinstate them and pay back wages.
– **National Labor Relations Commission (NLRC):** Reversed the Labor Arbiter’s decision, finding that the dismissal was not due to the labor complaint and noting procedural defects such as the submission of only photocopies of documents by Stanley Fine.
– **Court of Appeals (CA)**: Reinstated the Labor Arbiter’s decision, finding a grave abuse of discretion by the NLRC.
– **Supreme Court (SC):** Elena Briones filed a petition challenging the CA decision, arguing the dismissal was justified because Gallano and Siarez refused to explain their absences and the “unmeritorious labor case” remark was an error by her counsel.
**Issues:**
1. Does Elena Briones have standing to file the petition for review on certiorari?
2. Were Gallano and Siarez illegally dismissed by Stanley Fine Furniture?
3. Is the statement “unmeritorious labor case” an admission against interest and binding against Stanley Fine?
4. Did the CA err in awarding monetary claims and damages to Gallano and Siarez?
**Court’s Decision:**
1. **Standing:** The SC ruled that Elena Briones, as the sole proprietor of Stanley Fine, has standing to file the petition.
2. **Illegal Dismissal:** The SC affirmed the CA’s ruling that Gallano and Siarez were illegally dismissed. The SC found no valid grounds for dismissal and that procedural due process was not followed, i.e., there was no proper notice of termination or a hearing as required by Article 277(b) of the Labor Code.
3. **Admission Against Interest:** The SC upheld that the “unmeritorious labor case” statement in Stanley Fine’s position paper is an admission against interest, reinforcing the illegal dismissal claim. Errors by counsel generally bind the client unless it results in grave injustice, which was not demonstrated here.
4. **Monetary Awards:** The SC validated the CA’s decision to award monetary claims based on the lack of substantial evidence presented by Elena Briones to counter the claims. Annexed documents failed to meet evidentiary standards, many being unsigned or without complete details.
**Doctrine:**
The SC reiterated that terminating employment as a retaliation for asserting legal rights is illegal under the Labor Code. Employers must comply with substantive and procedural due process in dismissing employees. Admissions against interest in legal pleadings are binding unless shown to be made through palpable mistakes.
**Class Notes:**
– **Retaliatory Dismissal:** Illegal and violates security of tenure (Labor Code Art. 282(a-e)).
– **Burden of Proof:** Employer must prove non-dismissal or justify legal dismissal (Labor Code Art. 277(b)).
– **Procedural Due Process:** Requires two written notices – (1) specifying grounds for termination, and (2) notice of termination after hearing (Labor Code Art. 277(b); Omnibus Rules, Book VI, Rule I, Sec. 2(d)).
– **Admissions Against Interest:** Statements in legal pleadings are binding absent palpable error (Evidence Rule).
– **Employee Rights:** Filing a labor complaint negates allegations of work abandonment.
**Historical Background:**
This case reflects the continued judicial reinforcement of worker’s rights in Philippine labor law, particularly emphasizing the protection against retaliatory dismissals. It showcases the judiciary’s role in ensuring employers adhere to due process and the substantive rights enshrined in the Labor Code, reflecting the evolving labor relations dynamics and strengthening the legal framework for employee welfare amidst economic development.
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