Case #20Clarion Printing House vs. NLRCJune 27, 2005

Facts:Respondent Miclat was employed as probationary employee by petitioner Clarion. Then, the whole EYCO Group of Companies, of which Clarion was part, was put under receivership rehabilitation. Miclat was terminated as part of cost-cutting measures by petitioner. Miclat therefore filed a complaint for illegal dismissal against Clarion. Meanwhile, a temporary partial shutdown of some of the operations of the Company was implemented. The labor arbiter found that Miclat was illegally dismissed and directed her reinstatement. By Resolution, NLRC affirmed. CA sustained the resolutions of the NLRC.

Issue:Whether or not nominal damages may be awarded?

Ruling:The Supreme Court deemed it proper to award the amount equivalent to Miclat’s one month salary as nominal damages to deter employers from future violations of the statutory due process rights of employees. Therefore, Php 6,500.00 was awarded as nominal damages for non-compliance with statutory due process.