Case Digest: Negros Slashers v. Teng

G.R. No. 187122 : February 22, 2012




Alvin Ten, a professional basketball player, signed a 3-year contract with the Laguna Lakers. Before the expiration of his contract with the Laguna Lakers on December 31, 2001, the Lakers traded and/or transferred Teng to petitioner Negros Slashers, with the latter assuming the obligations of Laguna Lakers under Tengs unexpired contract, including the monthly salary of P250,000, P50,000 of which remained to be the obligation of the Laguna Lakers.

Teng executed with the Negros Slashers the Players Contract of Employment.
On Game Number 4 of the MBA Championship Round for the year 2000 season, Teng had a below-par playing performance. Because of this, the coaching staff decided to pull him out of the game. On the following game, Teng called-in sick and did not play.

Vicente Tan, Finance Head of Negros Slashers, wrote Teng requiring him to explain in writing why no disciplinary action should be taken against him for his precipitated absence during the crucial Game 5 of the National Championship Round. On the rescheduled hearing,the investigation proceeded, attended by Tengs representatives, Atty. Arsenio Yulo and Atty. Jose Aspiras.

Thereafter, the management of Negros Slashers decided to terminate the service of Teng for the team.

Consequently, Teng filed an illegal dismissal case with the Labor Arbiter. The Labor Arbiter issued a decision finding Tengs dismissal illegal

The case was then appealed to the NLRC, which reversed the LA's ruling.
On appeal, the CA reinstated the findings of the Labor Arbiter that Teng was illegally dismissed because the grounds relied upon by petitioners were not enough to merit the supreme penalty of dismissal. The CA held that there was no serious misconduct or willful disobedience or insubordination on Tengs part. Hence, this petition.

ISSUE: Whether or not the respondent was illegally dismissed.

HELD: The CA's decision was sustained by the Supreme Court.


The court find that the penalty of dismissal handed out against Teng was indeed too harsh. The court understand petitioners in asserting that a basketball organization is a team-based enterprise and that a harmonious working relationship among team players is essential to the success of the organization. We also take into account the petition of the other team members voicing out their desire to continue with the team without Teng. We note likewise the sentiments of the players and coaching staff during the meeting of February 4, 2001 stating how they felt when Teng abandoned them during a crucial Game Number 5 in the MBA championship round.

As an employee of the Negros Slashers, Teng was expected to report for work regularly. Missing a team game is indeed a punishable offense. Untying of shoelaces when the game is not yet finished is also irresponsible and unprofessional. However, we agree with the Labor Arbiter that such isolated foolishness of an employee does not justify the extreme penalty of dismissal from service. Petitioners could have opted to impose a fine or suspension on Teng for his unacceptable conduct. Other forms of disciplinary action could also have been taken after the incident to impart on the team that such misconduct will not be tolerated.


Ordinarily, rules of procedure are strictly enforced by courts in order to impart stability in the legal system. However, in not a few instances, we relaxed the rigid application of the rules of procedure to afford the parties the opportunity to fully ventilate their cases on the merits. This is in line with the time honored principle that cases should be decided only after giving all the parties the chance to argue their causes and defenses. In that way, the ends of justice would be better served. For indeed, the general objective of procedure is to facilitate the application of justice to the rival claims of contending parties, bearing always in mind that procedure is not to hinder but to promote the administration of justice.
Here, besides the fact that a denial of the recourse to the CA would serve more to perpetuate an injustice and violation of Tengs rights under our labor laws, we find that as correctly held by the CA, no intent to delay the administration of justice could be attributed to Teng. The CA therefore did not commit reversible error in excusing Tengs one-day delay in filing his motion for reconsideration and in giving due course to his petition for certiorari.