- Petitioner
- Heirs of Eleuterio O. Pasague
- Respondent
- Manila North Harbor Port
- Citation
- G.R. No. 231634
- Court
- Supreme Court
- Decided
- November 20, 2017
Validity of employment termination due to tuberculosis under authorized causes provision of the Labor Code
Summary
The heirs of deceased employee Eleuterio O. Pasague challenged his termination by Manila North Harbor Port, Inc. due to tuberculosis. The Supreme Court affirmed the Court of Appeals decision upholding the validity of the termination under Article 284 of the Labor Code as an authorized cause, since Eleuterio suffered from tuberculosis not curable within six months and his continued employment would be prejudicial to the health of co-employees. The Court cited established jurisprudence allowing termination for health reasons when supported by medical certification from competent public health authorities. However, the employer's failure to comply with Labor Code notice requirements entitled the employee to nominal damages. This case reinforces the balance between protecting workplace health and ensuring procedural due process in employment termination.
Focus of dispute
Validity of employment termination due to tuberculosis under authorized causes provision of the Labor Code
Legal facts
Eleuterio O. Pasague was an employee of Manila North Harbor Port, Inc. who was terminated from employment due to tuberculosis, a disease not curable within six months. The employer failed to comply with the notice requirements under the Labor Code. The heirs of Eleuterio, represented by his wife Helen D. Pasague and children, challenged the termination. Medical certification was issued by a competent public health authority confirming the disease.
Judgement and reasoning
Court of Appeals (CA): The CA ruled in favor of respondents in its June 30, 2016 Decision and April 21, 2017 Resolution in CA-G.R. SP No. 136184, finding that the termination was valid under Article 284 of the Labor Code as authorized cause due to disease.
Supreme Court (SC): The SC denied the petition and affirmed the CA decision, ruling that Eleuterio was validly terminated for authorized cause under Article 284 of the Labor Code due to tuberculosis not curable within six months. The Court cited Wuerth Philippines v. Ynson, establishing that employers may terminate employees suffering from diseases whose continued employment is prohibited by law or prejudicial to health. However, since respondents failed to comply with Labor Code notice requirements, Eleuterio is entitled to nominal damages.