GR L 50492; (October, 1987) (Digest)
G.R. No. L-50492 October 27, 1987
VINCENT RIKER, petitioner, vs. HON. BLAS F. OPLE and MAYON IMPERIAL HOTEL, respondents.
FACTS
Petitioner Vincent Riker was verbally engaged as General Manager of respondent Mayon Imperial Hotel on a four-month probationary basis beginning May 1, 1976. A proposed two-year employment contract outlining benefits, including a monthly salary of P7,000.00, was prepared and signed by Riker but was never signed by the hotel. Riker performed his duties and received his full salary. However, within a short period, the hotel management found his performance unsatisfactory, citing lavish entertaining, occasional drunkenness, and complaints from employees who lodged a report with the Commission on Immigration against him for “un-Filipino activities.” On August 20, 1976, the hotel’s corporate secretary informed Riker that a working visa for him could not be secured and advised him to leave by August 23, 1976. Believing he was illegally dismissed, Riker filed a complaint for illegal dismissal and monetary claims with the Department of Labor.
ISSUE
The primary issues are: (1) whether Riker’s dismissal was legally justified, and (2) whether a valid employment contract existed and was violated by the hotel, entitling Riker to damages.
RULING
The Supreme Court dismissed the petition, upholding the dismissal. On the first issue, the Court affirmed that Riker was a managerial employee whose dismissal was based on a loss of trust and confidence. The employer’s findings of serious misconduct, including the cited behavioral issues and the formal complaint by hotel employees, were supported by substantial evidence. The legal standard does not require proof beyond reasonable doubt; it is sufficient that the employer has reasonable grounds to believe the employee is guilty of misconduct rendering him unworthy of the trust demanded by his position. On the second issue, the Court ruled that no perfected two-year contract existed. The proposed contract lacked the hotel’s signature, indicating an absence of consent, a fundamental requisite for a contract’s validity. This supported the hotel’s claim that the agreement was merely probationary. Furthermore, the Court noted Riker was paid his full salary and certain expenses, negating his monetary claims. Consequently, the dismissal was valid and no contract violation occurred.