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LILIA P. LABADAN v. FOREST HILLS ACADEMY/NAOMI CABALUNA

FACTS:

Lilian Labadan, a former employee of Forest Hills Mission Academy, filed a complaint against the school and its administrator, Naomi Cabaluna, for various labor violations. Labadan claimed that she was illegally dismissed and was not paid overtime pay, holiday pay, allowances, 13th month pay, and service incentive leave. She also alleged that tithes were deducted from her salary without her consent.

Forest Hills argued that Labadan was granted leave but did not return after the approved period, so they hired a temporary employee. They claimed that the deduction of tithes was required by the church and Labadan never questioned it. Additionally, Forest Hills denied the non-payment of overtime pay, holiday pay, and allowances due to the lack of evidence.

The Labor Arbiter ruled in favor of Labadan and ordered Forest Hills to pay her a total amount of P152,501.02 for illegal dismissal. However, the NLRC reversed the decision and dismissed Labadan's complaint. The Court of Appeals dismissed Labadan's petition for certiorari on technical grounds.

Labadan then filed a Petition for Review on Certiorari before the Supreme Court, arguing that the Court of Appeals misjudged in dismissing her petition without addressing the merits of her case. Despite the technicalities, the Supreme Court decided to hear the case and resolve it on its merits.

ISSUES:

  1. Whether the petitioner was illegally dismissed from her work as a teacher and registrar.

  2. Whether the petitioner waived her 13th month pay and service incentive leaves due to her prolonged absence.

  3. Whether the Court of Appeals committed an act of grave abuse of discretion in dismissing the petitioner's petition on technicalities.

RULING:

  1. The National Labor Relations Commission (NLRC) reversed and set aside the decision of the Labor Arbiter and dismissed the petitioner's complaint. The petitioner claims that the NLRC committed an act of grave abuse of discretion. However, the Court decides the case on its merits and rules that the NLRC did not commit any grave abuse of discretion.

  2. The petitioner argues that she did not waive her 13th month pay and service incentive leaves, despite her prolonged absence. The Court finds that the petitioner failed to state these claims in her affidavit attached to her position paper, thereby implying that she waived these benefits.

  3. The Court of Appeals dismissed the petitioner's petition on the ground of technicalities. However, the Court brushes aside these technicalities in the interest of substantial justice and decides the case on its merits.

PRINCIPLES:

  • Non-payment of docket fee at the time of the filing of a petition does not automatically call for its dismissal as long as the fee is paid within the applicable prescriptive or reglementary period.

  • In cases of illegal dismissal, it is the employer's burden to prove that the dismissal was for a valid or just cause.