El empresario no puede perjudicar al empleado que cumple con el deber de ser miembro de un jurado en un proceso penal. Si lo hace, extinguiendo el contrato, la decisión será anulada por los tribunales.
La ausencia del puesto de trabajo para formar parte del Jurado de un tribunal impide el despido. El Tribunal Superior de Justicia de Madrid ha establecido que las empresas no pueden castigar así a los empleados porque, de lo contrario, la sanción será considerada nula al lesionar el derecho a colaborar con la Administración de Justicia.
Se trata de la primera vez que un tribunal aborda las consecuencias que tiene la decisión empresarial de extinguir una relación laboral por la participación de uno de sus empleados como jurado, actividad que desempeñó varios días. Así lo reconoce el fallo: “No cuenta este órgano judicial con doctrina constitucional ni jurisprudencia que haya abordado la cuestión suscitada en el litigio”.
El caso trata de un trabajador cuya empresa acordó su despido disciplinario, aunque admitió que era improcedente. El empleado acudió a juicio pidiendo que se anulara la extinción de su contrato, con el argumento de que se adoptó por sus ausencias laborales al haber sido elegido como jurado en un proceso penal. El tribunal de instancia rechazó la nulidad y declaró el despido como improcedente.
Sin embargo, el empleado recurrió al Tribunal Superior de Justicia para que revisara tal decisión, porque se había lesionado el ejercicio del derecho fundamental a participar en la Administración de Justicia.
La Sala, al carecer de precedentes, ha resuelto la controversia con apoyo, como principal referencia, en la Ley del Jurado. Esta norma señala que la “función del jurado es, a efectos del ordenamiento laboral, un deber inexcusable de carácter público y personal”. A su vez, se basa en la sentencia del Constitucional 183/93 que declaró que no se podía vulnerar el derecho de los trabajadores a ausentarse del trabajo para votar, tal y como ocurría al incluir las elecciones políticas en el porcentaje de absentismo para calcular la variable a cobrar por los empleados.
De la doctrina contenida en esta sentencia del Constitucional, explica el fallo, se desprende con claridad que “el ejercicio de un derecho fundamental no puede obstaculizarse sin causa justificada”, así como que ello ocurre cuando “arrastra consecuencias negativas para el titular del derecho”.
Los magistrados concluyen señalando que “similar razonamiento se puede aplicar al trabajador que interviene como miembro del jurado en un proceso penal”.
En este sentido, la sentencia explica que “esta intervención tiene carácter de ejercicio de un derecho público, por expreso reconocimiento legal, con la particularidad de que no afecta al derecho de participación política, sino al derecho de tutela judicial efectiva en su concreto aspecto de derecho a colaborar con la Administración de Justicia”.
Por ello, los magistrados afirman que si dicha colaboración afecta a un trabajador suponiéndole “un perjuicio indebido, se la estaría lesionando el ejercicio de su derecho, y qué duda cabe que, si ese perjuicio consistiera en el despido del trabajador, ese despido sería nulo”.
En este caso, la Sala consideró probado que había un nexo causal entre las ausencias laborales y el despido, pese a los intentos de la compañía por desvirtuarlo incidiendo en el mal comportamiento del trabajador y en que desconocía que era miembro de un jurado. En este punto, la sentencia afirma: “No se comprende que una empresa que ve cómo un trabajador se ausenta cuatro días a la semana durante tres semanas seguidas, no se interesa por la situación”.
Además, estima que hay “lesión al ejercicio del derecho asociado al artículo 24.2 de la Constitución en su vertiente de indebida obstaculización al obligado deber de colaborar con la Administración de Justicia”. Por todo ello, “el despido es nulo”. (Rº 1333/2010, 11/06/10).
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