The Supreme Court held that an employer cannot legally terminate an employee based on illness without a valid medical certification from a competent public health authority. This case clarifies the strict requirements employers must meet to justify terminating employment due to an employee’s health condition. It emphasizes the importance of protecting employees from arbitrary dismissals and ensuring they receive due process.

Can an Employer Dismiss an Employee Based on “Partial Blindness”?

This case revolves around Romualdo Payong, Jr., a welder at Manly Express Inc., who was terminated after developing eyesight problems, specifically a cataract. Despite undergoing surgery, he was disallowed from returning to work and eventually received a termination letter citing the company’s poor business climate and his partial blindness. Payong filed a complaint for illegal dismissal, arguing that his termination was unlawful. The Labor Arbiter initially ruled against him, but the National Labor Relations Commission (NLRC) modified the decision, awarding him service incentive leave and 13th-month pay. The Court of Appeals ultimately sided with Payong, declaring his dismissal illegal, a decision that Manly Express Inc. challenged before the Supreme Court. At the heart of the matter is whether an employer can validly terminate an employee’s contract based on a medical condition without proper medical certification and due process.

The Supreme Court firmly sided with the employee, reinforcing the protection afforded to workers under the Labor Code. Article 284 of the Labor Code allows for the termination of an employee due to disease, but it is not a blanket permission. This article must be read in conjunction with Section 8, Rule I, Book VI of the Omnibus Rules Implementing the Labor Code, which lays out strict requirements.

Art. 284. Disease as ground for termination. – An employer may terminate the services of an employee who has been found to be suffering from any disease and whose continued employment is prohibited by law or is prejudicial to his health as well as to the health of his co-employees: …

The court emphasized that for a dismissal on the ground of disease to be valid, two critical requisites must be satisfied. First, the employee must indeed suffer from a disease that is incurable within six months, or that their continued employment poses a threat to their own health or that of their colleagues. Second, and equally important, a competent public health authority must issue a certification confirming the incurability or the potential health risk. These safeguards ensure that employers do not abuse the provision and that employees are not unfairly dismissed based on unsubstantiated health concerns.

In Payong’s case, Manly Express Inc. failed to provide the necessary medical certification. The company argued that Payong’s partial blindness justified his termination, but they did not present any evidence from a public health authority to support this claim. The Supreme Court found this lack of certification to be a fatal flaw in Manly’s case, as the burden of proving the validity of the dismissal rests squarely on the employer. The employer must prove that they complied with all legal requirements for a valid dismissal, including providing a medical certificate from a competent public health authority. Failing to meet this burden, the dismissal is deemed illegal.

Moreover, the Court noted the lack of procedural due process in Payong’s dismissal. An employer is obligated to provide the employee with two notices: the first, informing them of the grounds for their possible dismissal, and the second, communicating the employer’s decision to terminate their employment. These notices ensure that employees are aware of the allegations against them and have an opportunity to respond.

In Triple Eight Integrated Services, Inc. v. NLRC, the Supreme Court explicitly stated that:

The requirement for a medical certificate under Article 284 of the Labor Code cannot be dispensed with; otherwise, it would sanction the unilateral and arbitrary determination by the employer of the gravity or extent of the employee’s illness and thus defeat the public policy on the protection of labor….

The absence of this certification opens the door to arbitrary dismissals based on an employer’s subjective assessment of an employee’s health, undermining the protections afforded to workers under the Labor Code. Furthermore, the Court found that Manly failed to prove Payong’s alleged refusal to undergo medical treatment or his voluntary resignation. On the contrary, evidence suggested that Manly initiated the termination due to Payong’s partial blindness and the company’s financial difficulties.

In conclusion, the Supreme Court’s decision underscores the importance of adhering to the strict requirements for terminating an employee based on disease. The ruling reaffirms the right to due process, making sure that no employee faces arbitrary dismissal due to illness. Employers must act within the boundaries of the law and show respect for their employees’ rights.

FAQs

What was the key issue in this case?	The key issue was whether an employer could legally terminate an employee’s employment based on a medical condition (partial blindness) without obtaining a certification from a competent public health authority.
What does Article 284 of the Labor Code cover?	Article 284 allows an employer to terminate an employee if they suffer from a disease that makes continued employment prohibited by law or prejudicial to their or their co-workers’ health, provided certain conditions are met.
What is the medical certification requirement?	The employer must obtain a certification from a competent public health authority stating that the employee’s disease is incurable within six months or that their continued employment is prejudicial to health.
What happens if the employer does not get a medical certification?	If the employer fails to provide the required medical certification, the dismissal is considered illegal, and the employee may be entitled to reinstatement, backwages, and other remedies.
Does the employee need to be given notices before termination?	Yes, the employer must provide two notices: one informing the employee of the grounds for possible dismissal and another communicating the final decision to terminate employment.
Who has the burden of proving the validity of the dismissal?	The employer bears the burden of proving that the dismissal was valid and complied with all the requirements under the Labor Code.
What was the outcome for Romualdo Payong, Jr. in this case?	The Supreme Court affirmed the Court of Appeals’ decision, declaring Payong’s dismissal illegal and entitling him to reinstatement or separation pay and backwages.
Can an employee refuse medical treatment and still claim illegal dismissal?	Even if an employee refuses medical treatment, the employer is still required to obtain the necessary medical certification to justify the termination. In Payong’s case, the company also failed to demonstrate he had refused treatment.

This case reinforces the importance of protecting employees’ rights and adhering to the strict requirements of the Labor Code when considering termination due to health reasons. The decision serves as a reminder that employers must act responsibly and within the bounds of the law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MANLY EXPRESS INC. AND SIU ENG T. CHING VS. ROMUALDO PAYONG, JR., G.R. NO. 167462, October 25, 2005