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AKLAN ELECTRIC COOPERATIVE v. NLRC

FACTS:

The petitioner in this case filed a petition for certiorari and prohibition with a prayer for a writ of preliminary injunction and/or temporary restraining order, challenging the decision of the National Labor Relations Commission (NLRC) in NLRC Case No. V-0143-94. The NLRC decision reversed the decision of Labor Arbiter Dennis D. Juanon and ordered the petitioner to pay wages totaling P6,485,767.90 to the private respondents. The petitioner also challenged the resolution of the NLRC denying their motion for reconsideration. A temporary restraining order was issued by the court enjoining the NLRC from executing the decision. The factual background of the case involves several complainants who claimed non-payment of salaries and wages, 13th month pay, ECOLA, and other fringe benefits from the respondent, Aklan Electric Cooperative, Inc. (AKELCO), its general manager Atty. Leovigildo Mationg, and the board of directors. The complainants alleged that they were continuously performing their tasks and receiving salaries at the main office in Lezo, Aklan, prior to the temporary transfer of the AKELCO office to Kalibo, Aklan. They further alleged that despite a resolution to transfer the office, they continued to report for work at Lezo and were paid their salaries. The administrator of the National Electrification Administration (NEA) issued a letter not objecting to the action taken by respondent Mationg. However, another resolution was passed by the Board of AKELCO withdrawing the temporary designation of the office in Kalibo and ordering the resumption of daily operations at the main office in Lezo. The complainants who reported at the Lezo office from January 1992 to May 1992 were paid their salaries, but from June 1992 to March 18, 1993, they were not paid. On March 19, 1993, the complainants were allowed to draw their salaries again, except for a few who were not paid in April and May 1993. The respondents, on the other hand, claimed that the complainants voluntarily abandoned their work and defied the lawful orders of the AKELCO management. They also alleged that the complainants engaged in activities to protest the appointment of respondent Atty. Leovigildo Mationg as the new general manager and caused damage to AKELCO's facilities. The decision of the Labor Arbiter dismissed the complaints, but the NLRC reversed and ordered the payment of unpaid wages from June 16, 1992, to March 18, 1993.

This case involves a labor dispute between petitioner Aklan Electric Cooperative, Inc. (AKELCO) and private respondents, who are former employees of AKELCO. Private respondents filed complaints for non-payment of salaries and benefits for the period from June 16, 1992, to March 18, 1993.

The evidence presented by the complainants shows that services were indeed rendered during this period. Respondent Atty. Mationg, AKELCO's General Manager, responded to the request of the Office Manager, Mr. Leyson, to recommend payment for the services rendered. It is admitted by AKELCO that the complainants were paid their wages and benefits from January to May 1992 and from March 19, 1993, until the time the complaints were filed. However, AKELCO refused to pay the complainants for the period from June 16, 1992, to March 18, 1993, citing the principle of "no work, no pay." No proof was submitted by AKELCO to substantiate their claim that no work was performed during this period.

The Labor Arbiter initially dismissed the claims of the complainants, relying on the "no work, no pay" principle, which was advanced by AKELCO. However, the National Labor Relations Commission (NLRC) reversed the decision, concluding that complainants are entitled to their claims. The NLRC found no merit in AKELCO's arguments and ordered the company to pay the complainants.

AKELCO filed a motion for reconsideration, but it was denied by the NLRC. Thus, AKELCO brought the case to the Court, alleging that the NLRC committed grave abuse of discretion. AKELCO argued that the NLRC disregarded AKELCO's orders to transfer the company's office and the complainants' defiance of those orders. AKELCO also disputed the NLRC's findings that the complainants were entitled to their wages for the disputed period.

In this case, the petitioner, Philippine National Bank (PNB), seeks the review of the decision of the National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's ruling in favor of the private respondents, former PNB employees. The private respondents claimed that they rendered service to PNB from January to May 1992 and again from March 19, 1993, but not for the period from June 1992 to March 18, 1993. They alleged that PNB illegally collected fees and charges due to them and appropriated the collections among themselves. They are claiming salaries only for the period from June 1992 to March 1993. PNB argued that private respondents could not have worked at their Lezo office during the stated period because PNB transferred its business operation to Kalibo and brought all its records and equipment there. PNB also contended that the computation of the claims for wages and benefits submitted by private respondents is not proof of rendition of work. The Solicitor General and NLRC filed their respective comments, stating that the Court's jurisdiction on the case does not include a correction of NLRC's evaluation of the evidence and that factual findings of administrative bodies are entitled to respect when supported by substantial evidence. The private respondents argued that the review of NLRC's decision is limited to issues of jurisdiction or grave abuse of discretion and that NLRC's factual findings should be given great weight and finality when supported by substantial evidence. They also cited a resolution by PNB's Board of Directors as an admission that they are entitled to payment for services rendered. PNB disagreed and maintained that the review of NLRC's decision is proper in case of conflicts in factual findings and when the evidence is insufficient and insubstantial to support NLRC's findings.

ISSUES:

  1. Whether or not the NLRC committed grave abuse of discretion in reversing the Labor Arbiter's decision, thereby entitling the private respondents to unpaid wages from June 16, 1992, to March 18, 1993, despite their refusal to work under the management's directive to report at the Kalibo office.

  2. Whether the private respondents are entitled to wages for the period during which they did not report to the relocated Kalibo office, under the "no work, no pay" principle.

RULING:

  1. The Supreme Court found that the NLRC committed grave abuse of discretion in reversing the Labor Arbiter's decision. It held that there was no substantial evidence to support the conclusion that private respondents rendered services from June 16, 1992, to March 18, 1993, to entitle them to payment of wages.

  2. The claim for wages was dismissed by the Supreme Court. The Court found that the private respondents did not report to the relocated Kalibo office despite instruction and that their salaries withheld were justified under the "no work, no pay" principle.

PRINCIPLES:

  • Grave Abuse of Discretion An administrative agency's decision can be set aside when there is a gross misappreciation of evidence leading to an arbitrary conclusion.

  • No Work, No Pay Principle Under general labor law, wages are contingent upon the performance of work. If an employee does not render service, they are not entitled to receive wages unless illegally locked out, suspended, or dismissed.

  • Management Prerogative Employers have the inherent right to transfer employees or business operation locations, which must be adhered to unless shown to be performed in bad faith or with malice.

  • Substantial Evidence Requirement In administrative proceedings, factual findings and conclusions must be based on relevant evidence that reasonable minds might accept as adequate.

  • Burden of Proof In labor disputes, the party asserting a claim must provide competent proof of the labor performed to justify wage compensation.