FACTS:
The petitioner in this case is seeking to set aside the decision of the National Labor Relations Commission (NLRC) in NLRC Case No. 4-1206-85. The NLRC's decision directed the respondent Philippine Airlines (PAL) to pay the complainants their salaries during the period of their suspension and to delete the disciplinary action from their service records. The undisputed material facts are as follows:
The individual respondents are all Port Stewards of the Catering Sub-Department, Passenger Services Department of PAL. Their duties include preparing meal orders and checklists, setting up standard equipment, and inventorying commissary supplies and equipment.
On various occasions, deductions were made from the individual respondents' salaries for losses of inventoried items allegedly caused by mishandling of company properties. The individual respondents, represented by the union, made a formal notice regarding the deductions to PAL, but no action was taken. They filed a formal grievance, but it was not resolved within the time provided in the Collective Bargaining Agreement (CBA), so they deemed it resolved in their favor.
When the manager for Catering returned from vacation, a grievance meeting was scheduled. The individual respondents refused to conduct inventory work on certain dates. The manager resolved the grievance by denying the individual respondents' petition and stating that inventory of bonded goods was part of their duty. He also rationalized the salary deductions for losses.
The manager then issued a directive for the individual respondents to explain why no disciplinary action should be taken against them for not conducting ramp inventory. Their explanation was deemed unsatisfactory, and suspensions ranging from 7 days to 30 days were imposed.
The union filed another grievance, but it was denied. The suspensions were lifted for some of the individual respondents, but the union demanded reimbursement of their salaries during the period of suspension.
The petitioners filed a complaint for illegal suspension before the Arbitration Branch of the Commission. The labor arbiter dismissed the complaint, but the NLRC set aside the labor arbiter's order and ruled in favor of the individual respondents.
The petitioner is now seeking judicial review of the NLRC's decision, claiming that it acted with grave abuse of discretion.
ISSUES:
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Whether the suspension of the complainants is illegal.
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Whether the respondent PAL is obligated to pay the complainants their salaries during the period of suspension.
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Whether the disciplinary action should be deleted from the complainants' service records.
RULING:
- The suspension of the complainants is declared illegal. Respondent PAL is directed to pay the complainants their salaries corresponding to the respective period(s) of their suspension. The disciplinary action is to be deleted from the complainants' service records.
PRINCIPLES:
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Judicial review in labor cases only extends to determining whether or not there was grave abuse of discretion amounting to lack of jurisdiction on the part of the NLRC.
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Employees may be charged for the amount due to mishandling of company property resulting in losses, but the loss may only be cost price 1/10 selling price.
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Grievances should be resolved within the time period provided in the collective bargaining agreement. Failure to do so may result in the grievance being deemed resolved in favor of the employees.
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Employees may be subjected to disciplinary action, such as suspension, for failing to comply with employer directives or for committing infractions. However, the penalty imposed should be commensurate with the offense committed.