GR L 80347; (December, 1988) (Digest)
G.R. No. L-80347 December 29, 1988
MANILA MIDTOWN COMMERCIAL CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, HON. TEODORICO DOGELIO, CESAR O. SINGCO AND ROLANDO NARAL, respondents.
FACTS
Private respondents Cesar Singco and Rolando Naral were employed as protective coordinators at the Manila Midtown Hotel. On May 23, 1984, Singco reported security guard Rodrigo Manzano for allowing unauthorized persons into the hotel, resulting in Manzano’s transfer. Subsequently, on June 9, 1984, the private respondents were informed that Manzano had filed a report dated May 18, 1984, accusing them of “white slavery” or pimping activities. They denied the charges. Nevertheless, they were suspended on June 28, 1984. After a conference with management, they received a notice of dismissal on July 23, 1984, on the ground of breach of trust. The employees filed a complaint for illegal dismissal. The Labor Arbiter ruled in their favor, finding the dismissal illegal and ordering reinstatement with backwages and other monetary benefits. The National Labor Relations Commission (NLRC) affirmed the decision on appeal.
ISSUE
Whether the NLRC committed grave abuse of discretion in affirming the Labor Arbiter’s decision that the dismissal of the private respondents was illegal.
RULING
The Supreme Court ruled that the NLRC did not commit grave abuse of discretion. While breach of trust is a valid ground for dismissing employees in security-sensitive positions, it must be substantiated by clear and convincing evidence. The Court upheld the factual findings of the labor tribunals that the charge was based solely on the report of security guard Rodrigo Manzano, who had a motive to retaliate against the private respondents after being disciplined and transferred on their report. Critically, the private respondents were never given a genuine opportunity to confront Manzano or to present evidence in their defense during a formal investigation, constituting a denial of due process. The dismissal was deemed “too harsh, oppressive and precipitate.” On the ancillary issue of jurisdiction, the Court found that the petitioner, along with the impleaded individuals, had voluntarily submitted to the jurisdiction of the labor arbiter and the NLRC and could not raise the issue belatedly. The monetary awards were also sustained as the petitioner failed to disprove the claims. The petition was dismissed for lack of merit.