ROMMEL M. ZAMBRANO, ROMEO O. CALIPAY, JESUS L. CHIN, et al., petitioners vs. PHILIPPINE CARPET MANUFACTURING CORPORATION/ PACIFIC CARPET MANUFACTURING CORPORATION, DAVIDE. T. LIM, and EVELYN LIM FORBES, respondents.
G.R. No. 224099
June 21, 2017
FACTS:
On January 3, 2011,petitioners, who were employees of private respondent Philippine Carpet Manufacturing Corporation, were notified of the termination of their employment effective February 3, 2011 on the ground of cessation of operation due to serious business losses. They were of the belief that their dismissal was without just cause and in violation of due process because the closure of Phil Carpet was a mere pretense to transfer its operations to its wholly owned and controlled corporation, Pacific Carpet Manufacturing Corporation (PacificCarpet). They asserted that their dismissal constituted unfair labor practice as it involved the mass dismissal of all union officers and members of the Philippine Carpet Manufacturing Employees Association (PHILCEA).
In its defense, Phil Carpet countered that it permanently closed and totally ceased its operations because there had been a steady decline in the demand for its products due to global recession, stiffer competition, and the effects of a changing market. Thus, in order to stem the bleeding, the company implemented several cost-cutting measures, including voluntary redundancy and early retirement programs. Phil Carpet likewise faithfully complied with the requisites for closure or cessation of business under the Labor Code. The petitioners and the Department of Labor and Employment were served written notices one (1) month before the intended closure of the company. The petitioners’ •were also paid their separation pay and they voluntarily executed their respective Release and Quitclaim before the DOLE officials.
In the September 29, 2014 Decision, the Labor Arbiter dismissed the complaints for illegal dismissal and unfair labor practice. The NLRC affirmed the findings of the LA, which was subsequently affirmed by the CA.
ISSUES:
1. Whether or not the petitioners were dismissed from employment for a lawful cause.
2. Whether or not the petitioners’ termination from employment constitutes unfair labor practice.
3. Whether or not the quitclaims signed by petitioners are valid and binding.
HELD:
1. Yes. The petitioners were terminated from employment for an authorized cause. In this case, the LA's findings that Phil Carpet suffered from serious business losses which resulted in its closure were affirmed in toto by the NLRC, and subsequently by the CA. It is a rule that absent any showing that the findings of fact of the labor tribunals and the appellate court are not supported by evidence on record or the judgment is based on a misapprehension of facts, the Court shall not examine anew the evidence submitted by the parties.
Further, even if the petitioners refuse to consider these losses as serious enough to warrant Phil Carpet's total and permanent closure, it was a business judgment on the part of the company's owners and stockholders to cease operations, a judgment which the Court has no business interfering with. The only limitation provided by law is that the closure must be "bonafide in character and not impelled by a motive to defeat or circumvent the tenurial rights of employees. Thus, when an employer complies with the foregoing conditions, the Court cannot prohibit closure "just because the business is not suffering from any loss or because of the desire to provide the workers continued employment."
2. No. The dismissal of the petitioners did not amount to unfair labor practice. Unfair labor practice refers to acts that violate the workers' right to organize. There should be no dispute that all the prohibited acts constituting unfair labor practice in essence relate to the workers' right to self-organization. Thus, an employer may only be held liable for unfair labor practice if it can be shown that his acts affect in whatever manner the right of his employees to self-organize.
The general principle is that one who makes an allegation has the burden of proving it. The petitioners miserably failed to discharge the duty imposed upon them. They did not identify the acts of Phil Carpet, which, they claimed, constituted unfair labor practice. They did not even point out the specific provisions, which Phil Carpet violated.
3. Yes. The quitclaims were valid and binding upon the petitioners. Where the person making the waiver has done so voluntarily, with a full understanding thereof, and the consideration for the quitclaim is credible and reasonable, the transaction must be recognized as being a valid and binding undertaking.
In this case, the petitioners question the validity of the quitclaims they signed on the ground that Phil Carpet's closure was a mere pretense. As the closure of Phil Carpet, however, was supported by substantial evidence, the petitioners' reason for seeking the invalidation of the quitclaims must necessarily fail. Further, as aptly observed by the CA, the contents of the quitclaims, which were in Filipino, were clear and simple, such that it was unlikely that the petitioners did not understand what they were signing. Finally, the amount they received was reasonable as the same complied with the requirements of the Labor Code.
Wherefore, the SC affirmed the decision of the CA in toto.
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