In the Philippines, employees who are unjustly dismissed from their jobs are entitled to reinstatement without any loss of seniority rights or privileges. Furthermore, they are entitled to the payment of full backwages from the time their compensation was withheld until they are actually reinstated. This ruling protects employees from arbitrary dismissal and ensures they are compensated for the period they were illegally deprived of their livelihood.

Safeguarding Corporate Assets or ‘Power Play’? When Following Orders Leads to Dismissal

The case of Philippine Journalists, Inc. (PJI) vs. Michael Mosqueda revolves around the tumultuous aftermath of the 1986 EDSA revolution. After the revolution, PJI was sequestered by the Presidential Commission on Good Government (PCGG). Rosario Olivares, a shareholder, sought to regain control, leading to separate stockholders’ meetings and the creation of a Task Force, headed by Michael Mosqueda, respondent, to protect PJI’s assets based on the directives of the Olivares group. Consequently, the new management terminated Mosqueda’s employment, which triggered a legal battle over the legality of his dismissal and his entitlement to reinstatement and backwages.

The core issue before the Supreme Court was whether Mosqueda’s dismissal was justified, and, if not, whether he was entitled to backwages. The Labor Arbiter initially ruled in favor of Mosqueda, finding that his dismissal was illegal because he was merely following instructions to protect the company’s assets. The National Labor Relations Commission (NLRC) later reversed the Arbiter’s decision by deleting the award of backwages, damages and attorney’s fees. The Court of Appeals then reinstated the Arbiter’s award of backwages, leading PJI to elevate the case to the Supreme Court.

The Supreme Court affirmed the Court of Appeals’ decision with modification. The Court emphasized the well-established rule that factual findings of the Court of Appeals, especially when aligned with those of the Labor Arbiter and the NLRC, are conclusive and not subject to review. Both the Labor Arbiter and the NLRC found that Mosqueda’s dismissal was illegal. Following instructions to safeguard company assets was not a valid ground for termination. The Court found no compelling reason to overturn these concurrent factual findings. The court reiterated the protection that labor laws extend to employees.

The Court highlighted Article 279 of the Labor Code, which mandates reinstatement and full backwages for unjustly dismissed employees:

“An employee who is unjustly dismissed is entitled to reinstatement, without loss of seniority rights and other privileges, and to the payment of his full backwages, inclusive of allowances, and other benefits or their monetary equivalent, computed from the time his compensation was withheld from him (which, as a rule, is from the time of his illegal dismissal) up to the time of his actual reinstatement.”

Building on this, the Court cited Republic Act No. 6715, which reinforces the right of illegally dismissed employees to full backwages:

“Employees who are illegally dismissed are entitled to full backwages, inclusive of allowances and other benefits or their monetary equivalent, computed from the time their actual compensation was withheld from them up to the time of their actual reinstatement. If reinstatement is no longer possible, the backwages shall be computed from the time of their illegal termination up to the finality of the decision.”

The Supreme Court found that Mosqueda was entitled to full backwages. These should include allowances and other benefits or their monetary equivalent, computed from March 10, 1992, the date of his illegal dismissal, up to the time of his actual reinstatement. The modification clarified that the computation should begin on March 10, 1992, and not March 11, 1992, as the Court of Appeals erroneously stated.

FAQs

What was the key issue in this case?	The key issue was whether Michael Mosqueda’s dismissal was legal, and if not, whether he was entitled to reinstatement and backwages.
Why was Mosqueda initially dismissed?	Mosqueda was dismissed for allegedly acting against the company’s interests by following instructions from a specific shareholder group to protect company assets.
What did the Labor Arbiter initially rule?	The Labor Arbiter initially ruled that Mosqueda’s dismissal was illegal and ordered his reinstatement with backwages and damages.
How did the NLRC modify the Labor Arbiter’s decision?	The NLRC affirmed the illegal dismissal but deleted the award of backwages, damages, and attorney’s fees.
What was the Court of Appeals’ ruling?	The Court of Appeals granted Mosqueda’s petition and reinstated the Labor Arbiter’s award of backwages.
What was the Supreme Court’s decision?	The Supreme Court affirmed the Court of Appeals’ decision with a modification. It affirmed that Mosqueda was entitled to full backwages from the time of his illegal dismissal until his reinstatement.
On what legal basis did the Court award backwages?	The Court relied on Article 279 of the Labor Code and Republic Act No. 6715, which guarantee full backwages for illegally dismissed employees.
What is the significance of this case?	The case reinforces the protection afforded to employees against illegal dismissal and underscores their right to reinstatement and full backwages.

In conclusion, the Supreme Court’s decision in Philippine Journalists, Inc. vs. Michael Mosqueda affirms the rights of employees who are unjustly dismissed. The ruling reinforces the principle that employers must adhere to legal standards when terminating employment. It also ensures that illegally dismissed employees receive just compensation for their loss of income.

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: Philippine Journalists, Inc. vs. Michael Mosqueda, G.R. No. 141430, May 07, 2004