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STANFILCO - A DIVISION OF DOLE PHILIPPINES v. JOSE TEQUILLO

FACTS:

The petitioner, Stanfilco, is a domestic corporation that operates a banana plantation. The private respondent, Jose Tequillo, was employed by the petitioner as a Farm Associate. Tequillo was terminated from his employment on May 24, 2010 for mauling his co-worker, Resel Gayon, and consuming intoxicating beverages within the company premises and during work hours.

On September 12, 2009, petitioner held a company-initiated employee gathering called the "Kaibigan Fellowship". Instead of attending the gathering, Tequillo opted to go drinking with fellow workers. Gayon, who was sent to assist Tequillo, met the group and was eventually mauled by Tequillo. Petitioner then served Tequillo with a memorandum, requiring him to explain his actions.

Administrative hearings were conducted, and petitioner found Tequillo's explanations unsatisfactory, leading to his termination on the ground of serious misconduct. Tequillo filed a complaint for illegal dismissal with the Labor Arbiter (LA).

The LA ruled in favor of the petitioner, stating that Tequillo's acts constituted serious misconduct and willful disobedience to company rules, justifying his dismissal. Tequillo appealed to the National Labor Relations Commission (NLRC), which reversed the LA's decision, declaring Tequillo's dismissal illegal. Petitioner sought reconsideration from the NLRC but was unsuccessful. Petitioner then filed a petition for certiorari before the Court of Appeals (CA).

The CA affirmed the NLRC's decision, ruling that Tequillo's dismissal was illegal because the act of mauling his co-worker was not work-related and only amounted to simple misconduct.

The petitioner now seeks review on certiorari, claiming that the CA erred in ruling that no grave abuse of discretion attended the NLRC's decision declaring Tequillo's dismissal illegal.

ISSUES:

  1. Whether the Court has the power to decide Rule 45 petitions in labor cases.

  2. What is the remedy from an adverse decision or final order of the NLRC?

  3. What is the scope of a certiorari proceeding in labor cases?

  4. What questions of law does the Court enquire into in labor cases?

  5. Did the CA correctly determine whether the NLRC committed grave abuse of discretion in ruling on the case?

  6. What are the requisites for an employee's termination on the ground of serious misconduct?

  7. Did Tequillo's acts constitute serious misconduct?

  8. Whether the violence occurred during working hours and within company premises.

  9. Whether the violence was work-related.

RULING:

  1. Yes, the Court has the power to decide Rule 45 petitions in labor cases, but it is limited to reviewing questions of law.

  2. The remedy from an adverse decision or final order of the NLRC is to file a petition for certiorari before the CA on the ground of grave abuse of discretion.

  3. In a certiorari proceeding, the scope is limited to correcting acts rendered without jurisdiction, in excess of jurisdiction, or with grave abuse of discretion.

  4. In labor cases, the Court enquires into the legal correctness of the CA's determination of the presence or absence of grave abuse of discretion in the NLRC decision.

  5. No, the CA did not correctly determine whether the NLRC committed grave abuse of discretion in ruling on the case.

  6. The requisites for an employee's termination on the ground of serious misconduct are: (a) the misconduct must be serious, (b) it must relate to the performance of the employee's duties, and (c) it must have been performed with wrongful intent.

  7. The Court partly agrees with the CA's decision, as physical violence between and among employees may constitute serious misconduct regardless of when and where it occurred.

  8. Time and location do not determine whether violence should be classified as work-related. The determination depends on the underlying cause of or motive behind the violence.

  9. The violence was considered work-related as it was connected to the performance of the employee's duties and was rooted in workplace dynamics. The assault was occasioned by the employee's urge to get even for a perceived wrong, which constituted a valid cause that justified his termination.

PRINCIPLES:

  • Not every fight within a company would automatically warrant dismissal from service.

  • Workplace dynamics or connection with the performance of the employees' duties are necessary for a confrontation to be considered work-related.

  • Time and location do not determine whether violence is work-related; the determination depends on the underlying cause or motive.

  • Refusal to provide incentives due to failure to meet work quotas can be a valid cause for termination.

  • Serious misconduct, such as workplace violence, can justify an employee's termination.