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WUERTH PHILIPPINES v. RODANTE YNSON

FACTS:

The case involves two separate cases of illegal dismissal.

In the first case, Rodante Ynson was hired as the National Sales Manager (NSM) for Automotive by Wuerth Philippines, Inc. Ynson suffered a stroke and provided medical certificates stating his medical condition and the need to continue rehabilitation until July 2003. However, the company directed him to appear for an investigation regarding alleged violations and eventually terminated his employment for continued absences without filing a leave of absence. Ynson filed a complaint for illegal dismissal and non-payment of allowances and the Labor Arbiter ruled in his favor.

In the second case, the respondent, a National Safety Manager (NSM) of a mining company, was terminated without valid cause and in violation of due process. The Labor Arbiter ruled in favor of the respondent and ordered the petitioner to pay various amounts in backwages, separation pay, medical benefits, damages, and attorney's fees. The NLRC affirmed the decision with modifications, and then further reduced the awards after motions for reconsideration were filed. The respondent filed a Petition for Certiorari before the Court of Appeals (CA), which partially granted the petition. The CA held that the respondent's illness was an authorized cause for termination, but the petitioner failed to comply with the requirement of obtaining a medical certificate from a competent public health authority.

In the third case, a law student challenged his dismissal from a university due to his repeated failure to comply with academic requirements. The petitioner argued that his dismissal violated his right to education, but the CA ruled in favor of the university. The petitioner then appealed the case to the Supreme Court.

ISSUES:

  1. Whether the requirement for a medical certificate under Article 284 of the Labor Code can be dispensed with

  2. Whether the respondent's failure to attend the investigations and return to work justified his dismissal

  3. Whether the respondent's position as a managerial employee affects the justification for his dismissal

  4. Whether the termination of the respondent's employment was valid.

  5. Whether the respondent is entitled to monetary awards.

  6. Whether the respondent is entitled to temperate damages

  7. Whether the respondent is entitled to 13th month pay

  8. Whether the respondent is entitled to attorney's fees

RULING:

  1. The requirement for a medical certificate under Article 284 of the Labor Code cannot be dispensed with. Failure to secure the required certification from a competent public health authority would defeat the public policy on the protection of labor.

  2. The respondent's failure to attend the investigations and return to work was without any valid or justifiable reason. His conduct showed indifference and disregard of his work and employer's interest, manifesting gross dereliction of duties.

  3. The respondent's position as a managerial employee, being tasked with important functions and duties, required the full trust and confidence of his employer. The employer has the prerogative to dismiss an employee for cause, and the respondent's conduct justified his dismissal.

  4. The termination of the respondent's employment was valid. Employers are given wide discretion in terminating the employment of managerial personnel, and the mere existence of a basis for believing that the employee has breached the trust and confidence of the employer is sufficient for dismissal. In this case, the respondent's irresponsible conduct and failure to report to work or be available for scheduled hearings justified the termination of his employment.

  5. The respondent is not entitled to all the monetary awards granted by the Court of Appeals (CA). The Court modified the awards and held that the respondent is only entitled to compensation for the actual number of work days starting from June 5, 2003. The Court ruled that if there is no work performed by the employee, there can be no wage or pay unless the employee was illegally prevented from working, which was not the case here. The Court also held that the reimbursement of medical expenses should be based on actual proof of expenses incurred, such as official receipts, which the respondent failed to provide. Therefore, the CA's award of medical expenses should be negated. However, the Court affirmed the CA's award of temperate damages.

  6. The Court of Appeals (CA) awarded the respondent temperate damages in the amount of P100,000.00, but the Supreme Court (SC) reduced it to P50,000.00. The SC considered that the respondent's stroke was not debilitating and his health condition remained stable. Additionally, there were no instances of subsequent or recurring ailments that necessitated prolonged medical attention.

  7. The CA ruled that the respondent is entitled to 13th month pay, but the SC clarified that the 13th Month Pay Law applies only to rank-and-file employees and not to managerial employees like the respondent. However, the SC acknowledged that the respondent may still be entitled to the benefit in accordance with the existing company policy on the payment of 13th month pay and the number of days he actually worked. The exact amount, either the full or pro-rated amount, cannot be determined by the court.

  8. The SC found that attorney's fees may only be awarded when the employee is illegally dismissed in bad faith and is compelled to litigate or incur expenses to protect his rights due to the unjustified acts of the employer. Since the respondent was validly dismissed for unauthorized absences constituting gross dereliction of duties, and there was no evidence of bad faith in his dismissal, the SC ruled that the grant of attorney's fees cannot be sustained.

PRINCIPLES:

  • The requirement for a medical certificate under Article 284 of the Labor Code cannot be dispensed with, as it ensures the protection of labor.

  • Employers have the prerogative to dismiss an employee for cause, but the exercise of this power should not be oppressive or self-destructive.

  • The worker's right to security of tenure is not absolute and may be subject to dismissal for cause.

  • Managerial employees are held to higher standards of conduct and work ethic, given the important and crucial functions they perform in the organization.

  • Employers have wide discretion in terminating the employment of managerial personnel when there is a basis for believing that the employee breached the trust and confidence of the employer.

  • An employee who fails to work cannot be entitled to compensation unless the failure to work was due to the fault of the employer.

  • The burden of proving actual damages rests on the party claiming them, and damages must be proven with reasonable certainty.

  • Temperate damages may be awarded when there is pecuniary loss but the amount cannot be proved with certainty.

  • Temperate damages can be awarded in cases where it is proven that the claimant suffered some pecuniary loss, but the amount is not capable of being proved with certainty.

  • The 13th Month Pay Law applies only to rank-and-file employees and not to managerial employees.

  • The exact amount, either the full or pro-rated amount, of 13th month pay for a managerial employee can be determined in accordance with the existing company policy.

  • Attorney's fees may only be awarded when the employee is illegally dismissed in bad faith and is compelled to litigate or incur expenses to protect his rights due to the unjustified acts of the employer.