G.R. No. 200815, August 24, 2020
San Miguel Corporation, Petitioner, vs. Rosario A. Gomez, Respondent.

FACTS

Petitioner San Miguel Corporation (SMC) employed respondent Rosario A. Gomez in 1986, later assigning her as a coordinator in its Mailing Department. SMC terminated Gomez’s employment on December 20, 2002, on the ground of fraud and willful breach of trust. The dismissal stemmed from an investigation into anomalies involving SMC’s courier service arrangement with C2K Express, Inc. C2K’s president executed an affidavit alleging that Gomez had been collecting a 25% commission from payments to C2K and that she facilitated transactions for a separate group using fake C2K receipts, causing losses to SMC. SMC conducted an administrative investigation where Gomez presented her defense, after which she was found guilty.
Gomez filed an illegal dismissal case. The Labor Arbiter upheld the validity of her termination. The National Labor Relations Commission (NLRC) reversed this, finding illegal dismissal and ordering reinstatement with backwages and damages. The Court of Appeals affirmed the NLRC’s ruling, holding that the dismissal for loss of trust and confidence was not founded on clearly established facts.

ISSUE

Whether the Court of Appeals erred in affirming the NLRC’s finding that Gomez was illegally dismissed.

RULING

Yes, the Supreme Court reversed the Court of Appeals and reinstated the Labor Arbiter’s decision, ruling that Gomez was validly dismissed for loss of trust and confidence. The Court held that SMC complied with procedural due process by providing Gomez with notice and a hearing where she could present her evidence. On substantive grounds, loss of trust and confidence is a valid cause for dismissal under Article 297 (formerly 282) of the Labor Code for employees occupying positions of trust and confidence.
Gomez, as a coordinator handling courier services, held such a fiduciary position. The employer’s burden to prove a valid cause was sufficiently discharged. The affidavit from C2K’s president directly implicated Gomez in receiving commissions, and the subsequent audit revealed anomalies causing company losses. Proof beyond reasonable doubt is not required in administrative proceedings; substantial evidence suffices. The findings of the company investigator, supported by the sworn statement and audit, constituted substantial evidence of Gomez’s breach of trust. The NLRC and CA erred in disregarding this evidence and imposing a stricter standard of proof. Consequently, her dismissal was for a just cause.