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This case involves a complaint filed by a security guard, Jean Bagoy, against Dansart Security Force and Allied Services Company for underpayment of salaries and non-payment of various benefits. While the company claimed Bagoy had abandoned his work, he argued he was not fully paid. The Labor Arbiter ruled in Bagoy's favor but did not address his illegal dismissal claim. The NLRC overturned this based on DOLE reports favoring the company. The Court of Appeals then reinstated the Labor Arbiter's decision. The Supreme Court upheld the doctrine that any doubts in evidence between employer and employee must be resolved in the employee's favor, and the burden of proving payment is on the employer.

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46 views1 page

Sdqwea

This case involves a complaint filed by a security guard, Jean Bagoy, against Dansart Security Force and Allied Services Company for underpayment of salaries and non-payment of various benefits. While the company claimed Bagoy had abandoned his work, he argued he was not fully paid. The Labor Arbiter ruled in Bagoy's favor but did not address his illegal dismissal claim. The NLRC overturned this based on DOLE reports favoring the company. The Court of Appeals then reinstated the Labor Arbiter's decision. The Supreme Court upheld the doctrine that any doubts in evidence between employer and employee must be resolved in the employee's favor, and the burden of proving payment is on the employer.

Uploaded by

cpvinculado
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Dansart Security Force and Allied Services Company, Petitioner, vs.

Danilo Sarte and Jean Bagoy,


Respondent
G.R. No. 168495 | July 2, 2010 | Peralta, J.

SUMMARY: Respondent Jean O. Bagoy was employed by Dansart Security Force and Allied Services Company
to guard the establishments of its various clients. However, from April 1999 until November 2001, respondent
had allegedly been caught sleeping on the job and incurred absences without leave, for which he was given
notices of disciplinary action. Respondent filed with the Regional Arbitration Branch a Complaint against
petitioners for underpayment of salaries and non-payment of overtime pay, holiday pay, premium pay, 13th
month pay and service incentive leave pay. Petitioners countered that it was respondent who abandoned her
work beginning November 2001. Petitioners, likewise, presented several reports issued by the National
Capital Region, Department of Labor and Employment (DOLE) stating that all mandatory wage increases and
other related monetary benefits were complied with by petitioner security agency, in rebuttal of respondents
claim of non-payment of wages and benefits.

The Labor Arbiter issued a Decision favorable to respondent about her money claims, but did not rule on the
issue of illegal dismissal as this was not included in her complaint. The foregoing Decision was appealed to the
NLRC which held that the DOLE reports, stating that petitioner security agency had been complying with all
mandatory wage increases and other monetary benefits, should be given proper respect. Respondent filed a
petition for certiorari with the Court of Appeals under Rule 65, which held that the resolution of the NLRC
should be set aside, and the Labor Arbiters Decision be reinstated.

DOCTRINE:
The Court has repeatedly ruled that any doubt arising from the evaluation of evidence as between the
employer and the employee must be resolved in favor of the latter. Moreover, it is settled jurisprudence
that the burden of proving payment of monetary claims rests on the employer. The reason for the rule is that
the pertinent personnel files, payrolls, records, remittances and other similar documentswhich will show
that overtime, differentials, service incentive leave, and other claims of workers have been paidare not in
the possession of the worker but in the custody and absolute control of the employer. Thus, the burden of
showing with legal certainty that the obligation has been discharged with payment falls on the debtor.

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