G.R. No. 184452 , February 12, 2020
LUFTHANSA TECHNIK PHILIPPINES, INC., ANTONIO LOQUELLANO AND ARTURO BERNAL, PETITIONERS, V. ROBERTO CUIZON, RESPONDENT.

FACTS

Petitioner Lufthansa Technik Philippines, Inc. (LTP) is a corporation engaged in aircraft maintenance, repair, and overhaul. Respondent Roberto Cuizon was the MA2 Duty Manager at LTP’s Cebu Station. Petitioners terminated Cuizon’s employment on August 16, 2005, for loss of trust and confidence due to two incidents.
The first incident occurred on March 10, 2005, during an A01 Check of PAL Aircraft EI-BZE. An accidental engine light-up occurred during an ignition check performed by mechanics. Cuizon was called to the scene. Instead of immediately reporting the accidental light-up to the Maintenance Control Center (MA4) in Manila as per standard procedure, Cuizon first had the aircraft towed to the hangar and continued the check. When he eventually called MA4 Duty Manager Carlos Ramirez, he reported only that the engine fan blade was hard to rotate, concealing the light-up. His initial written report also omitted the light-up, contradicting the reports of the mechanics. He later submitted a revised report mentioning the light-up but claimed he had made an immediate verbal report to his superior, Antonio Loquellano, who denied it.
The second incident occurred on April 15, 2005, during an A12 Check of PAL Aircraft RP-C4008. Cuizon was the Duty Manager and Project Manager. During the towing of the aircraft to a run-up area, Cuizon took the headset from the trained Headset Man and assigned an inexperienced mechanic, Jonas Cabajar, to the role. Cuizon then left the towing crew to initiate hangar housekeeping and allowed wing walkers and tail guides to leave their positions before towing was complete. He also failed to ensure critical safety precautions were followed (pressurizing the hydraulic system, ensuring proper brake pressure, ensuring wing flaps were up) and failed to await clearance from the airport tower. The aircraft’s wing flap collided with a utility post, causing damage that cost LTP over US$35,000 in repairs and lease charges.
Cuizon was served with show cause memoranda for both incidents, charged with violating company safety rules. After he submitted explanations and a hearing was conducted, LTP dismissed him. Cuizon filed a complaint for illegal dismissal, alleging he was singled out due to an anonymous letter critical of Loquellano that praised Cuizon. The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed his complaint, but the Court of Appeals reversed, finding his dismissal illegal.

ISSUE

Whether or not respondent Roberto Cuizon was illegally dismissed.

RULING

No, the Supreme Court ruled that Cuizon was validly dismissed for just cause. The Court found that the totality of Cuizon’s actions in the two incidents constituted willful breach of the trust reposed in him by his employer, amounting to gross negligence and warranting dismissal based on loss of trust and confidence.
Regarding the first incident (concealment of the accidental light-up), the Court found Cuizon failed to follow the standard operating procedure of immediately informing the MA4 in Manila. His initial reports deliberately concealed the fact of the accidental light-up, which was a serious safety event. His claim of having verbally reported it to Loquellano was uncorroborated and belied by his own written reports. His actions showed a lack of candor and a failure to act with the diligence required of a manager.
Regarding the second incident (towing incident), the Court found Cuizon grossly negligent. He improperly assumed the role of the Headset Man, assigned an unqualified substitute, abandoned the towing operation, allowed safety personnel to leave their posts, and failed to observe critical pre-towing safety checks and tower clearance protocols. These deliberate disregard of established safety procedures directly caused substantial financial damage to the company.
The Court held that as a managerial employee, Cuizon was tasked with ensuring strict adherence to safety protocols critical to the aviation industry. His repeated and serious violations in two separate incidents, which compromised aircraft safety and caused significant company loss, amply demonstrated that he breached the trust and confidence essential to his position. The dismissal was based on clear and convincing evidence of just cause, and due process was observed through the twin-notice requirement and a hearing. The Decision of the Court of Appeals was reversed and set aside, and the NLRC Decision dismissing the illegal dismissal complaint was reinstated.