GR 110321; (July, 1995) (Digest)
G.R. No. 110321 July 7, 1995
HILARIO VALLENDE, ET AL., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, TOP CENTER PROCESSING BACOLOD, INC. and/or JOSE SEPULVEDA, Manager, respondents.
FACTS
Petitioners were members of the Charlie Team harvest crew for respondent Top Center Processing, Inc., a prawn exporter. Their duties involved sorting, weighing, packing, and crating prawns. In August 1991, the company issued a memorandum warning of known pilferages involving the use of defective weighing scales to create excess prawn weight. Subsequently, on January 10, 1992, petitioner Amer Tinosan discovered his salary had been withdrawn by co-petitioner Larry Dormido using a forged authorization. During the ensuing investigation, Tinosan informed the plant superintendent he was resigning because crew members were demanding their share from the sale of prawns pilfered during a harvest on December 29, 1991. Following this, petitioners Evelino Dagle, Edwin Tolentino, and Alan Cristales voluntarily provided additional details about the pilferage incident. The company suspended the Charlie Team, conducted a formal investigation with notice and opportunity to explain, and subsequently dismissed petitioners for gross misconduct.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the validity of petitioners’ dismissal on the ground of loss of trust and confidence.
RULING
The Supreme Court dismissed the petition, upholding the NLRC’s decision. The Court emphasized that factual findings of quasi-judicial agencies like the NLRC, when supported by substantial evidence, are accorded respect and finality. The detailed information regarding the pilferage scheme came directly from petitioners Tinosan, Cristales, Tolentino, and Dagle themselves, which provided a reasonable basis for the employer’s loss of confidence. The legal standard for dismissal on this ground does not require proof beyond reasonable doubt; it is sufficient that the employer has reasonable grounds to believe the employee committed the misconduct, rendering him unworthy of the trust demanded by his position.
Petitioners’ claim of procedural due process violation for not receiving a copy of a supplemental position paper was rejected. The essence of due process is the opportunity to be heard, which was satisfied through the company’s investigation, the formal hearing before the Labor Arbiter, and the petitioners’ subsequent appeal and motion for reconsideration before the NLRC. Any technical defect was deemed cured by these appellate opportunities. Thus, the dismissal was valid for loss of trust and confidence, a ground applicable to employees charged with care and custody of the employer’s goods.