G.R. No. 203186 ; December 4, 2013
XAVIER C. RAMOS, Petitioner, vs. BPI FAMILY SAVINGS BANK INC. and/or ALFONSO L. SALCEDO, JR., Respondents.

FACTS

Petitioner Xavier C. Ramos was the Vice-President for Dealer Network Marketing/Auto Loans Division of respondent BPI Family Savings Bank. A fraudulent auto loan was obtained in the name of a client, Trezita Acosta, resulting in a bank loss of over two million pesos. An investigation revealed that Ramos had issued a Purchase Order and Authority to Deliver the vehicle without the prior approval of the bank’s credit committee. Furthermore, his subordinates failed to verify the applicant’s identity as required by the bank’s “Know Your Customer” protocols. Consequently, BPI Family deducted ₱546,000.00 from Ramos’s retirement benefits as his proportionate share of the loss. Ramos filed a complaint for illegal deduction, which the Labor Arbiter dismissed. The National Labor Relations Commission (NLRC) reversed the Arbiter, ordering a refund of the deducted amount.

ISSUE

Whether the Court of Appeals erred in modifying the NLRC decision and finding Ramos concurrently negligent, thereby justifying an equitable reduction of his retirement benefits.

RULING

The Supreme Court granted the petition and reinstated the NLRC decision. The Court held that the CA gravely abused its discretion in finding Ramos negligent. The legal logic centered on the principle that a petition for certiorari under Rule 65 requires a showing that the NLRC acted with grave abuse of discretion amounting to lack or excess of jurisdiction. The NLRC’s findings were based on substantial evidence: Ramos, as a division head, could not be expected to personally examine all loan documents or verify every client’s identity, as these were duties delegated to his subordinates. The NLRC also found that the practice of issuing documents prior to credit committee approval was an ordinary bank procedure. Since the NLRC’s conclusions were supported by evidence and not tainted by arbitrariness, the CA overstepped by re-evaluating the facts and substituting its own judgment. The CA’s attribution of concurrent negligence was thus an erroneous exercise of certiorari power. The quitclaim Ramos signed was also deemed ineffective as it was executed under the coercive circumstance of the illegal deduction. Therefore, the deduction was illegal, and Ramos was entitled to a full refund of the ₱546,000.00 deducted from his retirement benefits.