G.R. No. 246531 , October 04, 2023
BENEDICT PRINCER SAN JUAN, PETITIONER, VS. REGUS SERVICE CENTRE PHILIPPINES B.V., RESPONDENT.

FACTS

Petitioner Benedict Princer San Juan, a Network Operations Manager, was dismissed by respondent Regus following a team-building event. During the event, San Juan was reported to have been heavily intoxicated and was involved in a serious incident with his subordinate, Ruben Cruz. Cruz alleged that San Juan sexually molested him while they shared a bed in a female employees’ room. Regus conducted an investigation, interviewing multiple witnesses who corroborated accounts of excessive drinking and inappropriate behavior. San Juan admitted to intoxication and sleeping in the females’ room but denied the sexual assault, instead claiming Cruz was the aggressor. He was issued two Notices to Explain for indecent/scandalous behavior, sexual harassment, serious misconduct, and willful breach of trust. After administrative hearings, Regus terminated San Juan’s employment.
San Juan filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, finding the dismissal valid. The National Labor Relations Commission (NLRC) reversed, ruling the dismissal illegal, citing insufficient evidence and procedural flaws in the investigation. The Court of Appeals reinstated the Labor Arbiter’s decision, validating the dismissal. San Juan elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in ruling that San Juan was validly dismissed from employment.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, upholding the legality of San Juan’s dismissal. The Court emphasized that in termination cases, the employer bears the burden of proving just cause and observance of procedural due process. The standard of proof required is substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The Court found that Regus successfully discharged this burden.
On the substantive aspect, the acts committed by San Juan constituted serious misconduct and willful breach of trust. As a managerial employee, he held a position of responsibility and was expected to exemplify proper decorum. His admitted excessive intoxication, sleeping in a room with female subordinates, and his involvement in a scandalous incident of alleged sexual molestation demonstrated a flagrant disregard for company rules and behavioral standards. These actions eroded the trust and confidence essential to his managerial role. The Court held that the factual findings of the Labor Arbiter and the Court of Appeals, which were supported by substantial evidence from the investigation, were conclusive. The NLRC’s contrary findings were based on a misappreciation of evidence.
On procedural due process, the Court ruled that Regus complied with the twin-notice requirement. San Juan was given a first Notice to Explain detailing the charges. He participated in administrative hearings with counsel and was afforded the opportunity to present his side. A second notice followed, informing him of the decision to terminate and the reasons for it. The Court clarified that a formal trial-type hearing is not required; what is essential is the opportunity to be heard. The investigation conducted by Regus, which included witness interviews and consideration of San Juan’s written explanation, satisfied this requirement. Therefore, the dismissal was for a just cause and effected with due process.