FACTS:
Petitioner Charlito Peñaranda was employed by Baganga Plywood Corporation (BPC) in June 1999 to oversee the operations and maintenance of its steam plant boiler. In May 2001, Peñaranda filed a Complaint for illegal dismissal against BPC and its general manager, Hudson Chua, before the National Labor Relations Commission (NLRC). After failing to settle amicably, the labor arbiter directed both parties to submit their position papers and supporting documents. Peñaranda claimed that he was employed by BPC on March 15, 1999, with a monthly salary of P5,000 as a Foreman/Boiler Head/Shift Engineer, and was illegally terminated on December 19, 2000. On the other hand, BPC claimed that Peñaranda's separation from service was in compliance with Article 283 of the Labor Code, as it temporarily closed for repair and maintenance and applied for clearance with the Department of Labor and Employment (DOLE) to shut down and dismiss employees. The labor arbiter ruled that there was no illegal dismissal and that Peñaranda's Complaint was premature because he was still employed by BPC. The labor arbiter found Peñaranda entitled to overtime pay, premium pay for working on rest days, and attorney's fees. Respondents appealed to the NLRC, which deleted the award of overtime pay and premium pay, stating that Peñaranda was a managerial employee and therefore not entitled to these benefits. The Court of Appeals dismissed Peñaranda's Petition for Certiorari, as he failed to attach copies of the pleadings submitted to the labor arbiter and NLRC and did not explain why the filing and service of the Petition was not done by personal service.
ISSUES:
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Whether the NLRC committed grave abuse of discretion in entertaining the appeal despite the lapse of the mandatory period of ten days.
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Whether the NLRC committed grave abuse of discretion in reversing the factual and legal findings of the labor arbiter regarding the employee's entitlement to monetary benefits and overtime pay.
RULING:
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The Court did not discuss the first issue raised by the petitioner regarding the alleged grave abuse of discretion in entertaining the appeal despite the lapse of the mandatory period of ten days. The Court focused solely on the second issue regarding the entitlement to monetary benefits and overtime pay.
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The Court affirmed the ruling of the NLRC that the petitioner, being a managerial employee, is not entitled to overtime pay and premium pay for working on rest days. The Court ruled that managerial employees and members of the managerial staff are exempted from the provisions of the Labor Code on labor standards. Thus, the decision of the NLRC reversing the labor arbiter's award of overtime pay and premium pay was upheld.
PRINCIPLES:
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Managerial employees and members of the managerial staff are exempted from the provisions of the Labor Code on labor standards.
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Managerial employees are not entitled to overtime pay and premium pay for working on rest days.