53 Philippine Spring Water v. CA

Philippine Spring Water v.
CA
G.R. No. 205278 June 11, 2014
Overview
PSWRI had an inaugural day together with their Christmas party and over-all chairmanship of the activity
was assigned to Mahilum, the latter was not seen around to supervise the program proper as he
entertained some visitors of the company. Mahilum’s attention was, however, called when Lua got
furious because he was not recognized during the program. For thi reason, he was suspended until he
was dismissed.
Mahilum was a regular employee who was entitled to security of tenure. Thus, he could only be
dismissed from service for causes provided in Article 282 of the Labor Code.
[FACTS:]
-The inauguration of PSWRI’s Bulacan plant would be celebrated at the same time with the company’s
Christmas party. Mahilum was designated as over-all chairman of the affair to be held on December 19,
2004.
-Thereafter, meetings on the program of activities for the inauguration and Christmas party were
conducted without Mahilum’s presence. Evangelista took charge and assumed the lead role until the
day of the affair.
-On the inaugural day, Mahilum was not seen around to supervise the program proper as he entertained
some visitors of the company. According to him, he delegated the task to Evangelista.
-Mahilum’s attention was, however, called when Lua(PRESIDENT/CEO) got furious because he was not
recognized during the program.
-On the following day, Mahilum was required to explain why Lua was not recognized and made to
deliver his speech. At the same time, he was placed under preventive suspension for thirty (30) days.
-When his 30-day suspension ended, Mahilum reported for work but was prevented from entering the
workplace. Sometime in the first week of March 2005, he received a copy of the Memorandum, dated
January 31, 2005, terminating his services effective the next day or on February 1, 2005. On February 9,
2005, a clearance certificate was issued to Mahilum. He received the amount of ₱43,998.56 and was
made to execute the Release, Waiver and Quitclaim in favor of the company and Lua.
Mahilum filed a complaint for illegal dismissal with prayer for reinstatement, payment of back wages
and damages.
LA – dismissed for lack of merit on the ground that the quitclaim he had executed barred his right to
question his dismissal under the principle of estoppel
NLRC - ruled in his favor on the ground that the subject quitclaim did not bar the institution of the case
for illegal dismissal. It held that while not all waivers and quitclaims were invalid as against public policy,
the LA’s consideration of the waiver did not constitute a reasonable settlement of his cause of action.
PSWRI and Lua filed a petition for certiorari with the CA.
CA - the CA reversed the NLRC decision. It ruled that Mahilum’s conduct during the inauguration did not
constitute wilful disobedience or breach of trust, hence, rendering his termination as illegal and without
cause. However, it upheld the validity of the executed quitclaim.
MR by Mahilum - Mahilum to have been indeed illegally dismissed from employment, the CA
ruled that he was entitled to full backwages and separation pay in lieu of reinstatement, in view
of the strained relations between Mahilum and Lua. With respect to the quitclaim, the CA
declared it to be void for having no consideration at all.
Hence, this petition for certiorari under Rule 65.

[ISSUES:]
W/n Mahilum was illegally dismissed?
[HELD:]
Yes. Mahilum was a regular employee who was entitled to security of tenure. Thus, he could only be
dismissed from service for causes provided in Article 282 of the Labor Code. At this point, it bears
stressing that the NLRC and the CA, in their decisions, both found Mahilum to have been illegally
dismissed.
The well-entrenched rule, especially in labor cases, is that findings of fact of quasi-judicial bodies, like
the NLRC, are accorded with respect, even finality, if supported by substantial evidence. Particularly
when passed upon and upheld by the CA, they are binding and conclusive upon the Court and will not
normally be disturbed.
Further, his designation as the chairman of the whole affair did not form part of his duty as a supervisor.
Mahilum was engaged to supervise the sales and marketing aspects of PSWRI’s Bulacan Plant. Verily, the
charge of loss of trust and confidence had no leg tostand on, as the act complained of was not work-
related. Simply put, the petitioners were not able to prove that Mahilum was unfit to continue working
for the company. Likewise, warranting the agreement of the Court is the finding of the CA in its
Amended Decision that the quitclaim executed by Mahilum did not operate to bar a cause of action for
illegal dismissal.

53 Philippine Spring Water v. CA

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Philippine Spring Water v.

Hence, this petition for certiorari under Rule 65.

W/n Mahilum was illegally dismissed?

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