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MADRIO VS.

ATLAS FERTILIZER CORPORATION

Facts: Petitioner was formerly Sales Manager of AFC. He filed a


complaint against AFC for the payment of several monetary and separation
benefits pursuant to AFC's policy. Petitioner attached an unsigned and
unauthenticated copy of the Retirement Plan.

AFC denied the said plan is the policy it had, and argued it would be
unreasonable to pay such benefits to petitioner, who caused whopping
financial loss due to gross negligence. Petitioner was given a chance but
unceremoniously left without obtaining any clearance or permission.

LA ruled in favor of petitioner. NLRC affirmed, reducing the benefits. CA


ruled the petitioner not entitled to benefits.

Issue: WON the NLRC gravely abused its discretion when it admitted the
Retirement Plan as evidence, and consequently, granted the award of
separation benefits.

Ruling: The Court agrees with the CA.


The print-outs, which constitute the only evidence of petitioners, afford no
assurance of their authenticity because they are unsigned. The decisions of
this Court have nonetheless consistently required some proof of
authenticity or reliability as condition for the admission of documents
Petitioner only submitted a copy of the Retirement Plan as proof of his
entitlement to the separation benefits claimed. It does not demonstrate that
the conditions for entitlement had been met by the employee.

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