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NITTO ENTERPRISES v. NLRC

FACTS:

Petitioner Nitto Enterprises hired Roberto Capili as an apprentice machinist, molder, and core maker with a daily wage rate of P66.75. On August 2, 1990, Capili accidentally injured the leg of an office secretary while handling a piece of glass. Later that day, Capili operated a power press machine without authority and injured his left thumb. The company covered his medical expenses. The following day, Capili was asked to resign by the company and was given a letter outlining the reasons for his resignation. Capili executed a Quitclaim and Release in favor of the petitioner and received payment in the amount of P1,912.79. Capili filed a complaint for illegal dismissal and payment of other benefits. The Labor Arbiter ruled in favor of the petitioner, but the NLRC reversed the decision, declaring Capili as a regular employee and ordering his reinstatement with back wages.

ISSUES:

  1. Whether or not the termination of the private respondent was valid

  2. Whether or not the private respondent was considered a regular employee

RULING:

  1. The termination of the private respondent was not valid. The National Labor Relations Commission (NLRC) ruled that the dismissal was illegal because the petitioner failed to provide valid cause for the termination. Thus, the NLRC ordered the reinstatement of the private respondent with backwages.

  2. The NLRC declared that the private respondent was a regular employee who enjoyed security of tenure as early as May 28, 1990. The apprenticeship agreement filed with the Department of Labor only on June 7, 1990 was not considered a valid basis for concluding that the private respondent was hired as a plain apprentice on May 28, 1990.

PRINCIPLES:

  • An employer has the burden of proving that the dismissal of an employee is for a valid cause. Without such proof, the dismissal will be deemed illegal.

  • The determination of whether an employee is a regular or an apprentice is based on the nature of the work and the actual performance of the employee, not merely on the existence of an apprenticeship agreement.