**Title:** JR Hauling Services and Oscar Mapue vs. Gavino L. Solamo, Ramil Jerusalem, Armando Parungao, Rafael Caparos, Jr., Noriel Solamo, Alfredo Salangsang, Mark Parungao, and Dean V. Calvo
**Facts:**
1. Petitioners JR Hauling Services and Oscar Mapue are engaged in hauling and delivering broiler chickens.
2. Respondents, formerly drivers/helpers at JR Hauling, were paid PHP 300 per trip and typically made one trip per day.
3. Petitioners claimed respondents incurred shortages in broiler deliveries and engaged in unauthorized selling of excess broilers and crates.
4. Petitioners presented affidavits from co-employees and a summary of short deliveries to support these allegations.
5. Respondents were dismissed from their jobs on April 3, 2011, allegedly without notice or hearing.
6. Respondents filed a complaint for illegal dismissal, underpayment/non-payment of wages, 13th month pay, holiday pay, rest day pay, SIL pay, seeking reinstatement, back wages, and attorney’s fees.
**Procedural Posture:**
1. **Labor Arbiter (LA) Decision (December 9, 2011):** Ruled in favor of the respondents (employees) for illegal dismissal due to lack of just cause and due process. Ordered reinstatement with back wages and salary differentials, but denied claims for 13th month pay, holiday pay, and SIL.
2. **NLRC Decision (August 28, 2012; November 15, 2012):** Reversed the LA’s decision, finding respondents’ dismissal valid due to loss of trust and confidence supported by co-employees’ affidavits. This decision dismissed respondents’ claim.
3. **Court of Appeals Decision (September 5, 2014):** Set aside the NLRC ruling and reinstated the LA decision. The CA found the affidavits insufficient as substantial evidence to justify the dismissal.
**Issues:**
1. **Substantial Evidence:** Did petitioners provide substantial evidence to prove just cause for the respondents’ dismissal?
2. **Monetary Claims:** Are respondents entitled to salary differentials and other monetary claims?
3. **Procedural Due Process:** Did petitioners comply with the required procedural due process in dismissing respondents?
**Court’s Decision:**
1. **Substantial Evidence:**
– The Supreme Court did not find the unsigned and unauthenticated summary of short deliveries sufficient to establish respondents’ involvement in the alleged shortages of broilers.
– Affidavits presented by petitioners were substantial evidence for the unauthorized sale of excess broilers and broiler crates. Such affidavits corroborated respondents’ involvement.
– Despite affidavits being taken ex parte, they held weight due to the presumption of regularity, absent compelling contradictory evidence from respondents.
– The Court differentiated between the claims of delivery shortages and unauthorized sales, giving merit to affidavits on the latter.
2. **Procedural Due Process:**
– Petitioners failed to provide written notices required for due process and neglected respondents’ claims of being barred from the premises.
– Even if respondents did not report to work, petitioners still had the duty to serve written notices by registered mail if needed.
– As a result, dismissal was substantively justified but procedurally defective; respondents were awarded PHP 30,000 each in nominal damages for this failure.
3. **Monetary Claims:**
– Respondents were entitled to salary differentials as petitioners failed to show that wages met the regional minimum, considering evidence of an average daily wage was only PHP 300 compared to the legally mandated minimum.
– The Supreme Court upheld the CA’s reinstated order for payment of salary differentials.
Finally, the Supreme Court ruled to Reinstate the CA decision with modifications:
– Respondents were declared to have been dismissed with cause but awarded PHP 30,000 each for procedural due process violations.
– **Reinstatement Claim:** Recalculation of salary differentials as part of compliance.
**Doctrine:**
1. **Substantial Evidence Rule:** Quantum of proof required to justify employee dismissal is substantial evidence, not proof beyond reasonable doubt.
2. **Procedural Due Process in Dismissals:** Requires written notice before termination, allowing the employee an opportunity to contest, which was violated in this instance.
**Class Notes:**
– **Substantial Evidence:** Defined as relevant evidence that reasonable minds accept as adequate to support a conclusion. It’s the lower threshold standard required in labor disputes.
– **Procedural Due Process:** Involves a two-notice rule: notice to explain and notice of termination.
– **Art. 297 of the Labor Code:** Defines just causes for termination including serious misconduct and willful breach of trust.
– **Affidavits in Labor Cases:** Can serve as substantial evidence without need for cross-examination, unlike in regular judicial proceedings.
**Historical Background:**
This case reflects the complexities around labor law in the Philippines concerning ‘just cause’ and ‘due process’ in employee dismissals. It underscores the balance courts maintain between protecting workers’ rights and permitting reasonable employer discretion rooted in trust and performance within a regulatory and judicial framework that evolved from post-colonial labor struggles to modern industrial relations.
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