G.R. No. 154410 . October 20, 2005.
HEAVYLIFT MANILA, INC., JOSEPHINE EVANGELIO, and CAPT. ROLANDO TOLENTINO, Petitioners, vs. THE COURT OF APPEALS, MA. DOTTIE GALAY and the NATIONAL LABOR RELATIONS COMMISSION, Respondents.

FACTS

Petitioner Heavylift Manila, Inc., a maritime agency, terminated respondent Ma. Dottie Galay, an Insurance and Provisions Assistant, on August 16, 1999, for alleged loss of confidence. The termination followed a February 1999 letter citing her low performance rating and negative feedback from team members regarding her work attitude. Galay filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, finding the dismissal illegal due to petitioners’ failure to prove a violation of company regulation and to provide proper notice. The NLRC affirmed this decision.
Petitioners elevated the case to the Court of Appeals via a petition for certiorari. The appellate court dismissed the petition outright for procedural deficiencies: failure to state the full names and addresses of all petitioners, failure to attach all pertinent pleadings and documents, improper verification, and lack of a proper certification against forum-shopping. Petitioners’ motion for reconsideration, which attached a board resolution authorizing Tolentino to represent the company, was denied as the resolution was issued after the petition was filed.

ISSUE

The primary issues were: (1) whether the Court of Appeals erred in dismissing the petition on technical grounds, denying due process; and (2) whether “attitude problem” constitutes a valid ground for termination under the doctrine of loss of confidence.

RULING

The Supreme Court denied the petition. On the procedural issue, the Court held that while rules of procedure may be relaxed to serve substantial justice, petitioners’ multiple and serious procedural lapses—particularly the defective certification against forum-shopping and failure to attach critical documents—justified the Court of Appeals’ dismissal. The belated submission of the board resolution did not cure the initial fatal defects. The Court emphasized that procedural rules are designed for orderly adjudication and their strict application in this case was proper.
On the substantive issue of illegal dismissal, the Court affirmed the NLRC’s findings. For dismissal based on loss of confidence to be valid, it must be grounded on willful breach of trust by an employee entrusted with fiduciary duties, and must be supported by substantial evidence. The petitioners merely alleged an “attitude problem” and strained relationships without proving any specific act constituting a breach of trust relevant to Galay’s duties. General allegations of poor interpersonal relations, unsupported by concrete evidence, do not equate to loss of confidence that justifies termination. Consequently, the dismissal was illegal. The awards for service incentive leave and 13th month pay were also upheld as logical consequences of the illegal dismissal finding.