G.R. No. 100514. March 29, 1995. ZAMBOANGA CITY ELECTRIC COOPERATIVE, INC. (ZAMCELCO), petitioner, vs. HON. MUSIB M. BUAT, in his capacity as Presiding Commissioner, HON. OSCAR N. ABELLA and HON. LEON O. GONZAGA, JR., in their capacity as Commissioners, FIFTH DIVISION, NATIONAL LABOR RELATIONS COMMISSION (NLRC) and ENGR. PATRICIO S. DELA PEÑA, JR., respondents.
FACTS

Petitioner ZAMCELCO, an electric cooperative under NEA supervision, employed private respondent Patricio S. Dela Peña, Jr., who rose to become its General Manager. In 1986, the Board of Directors created a fact-finding committee to investigate alleged financial irregularities, implicating Dela Peña. Subsequently, three NEA audit teams investigated, with findings ranging from unliquidated cash advances to mismanagement and disregard of NEA guidelines, leading to recommendations for his suspension or dismissal. After being directed to explain and being placed under suspension, Dela Peña submitted a detailed written explanation. On July 15, 1988, ZAMCELCO’s Board passed a resolution terminating his services on grounds of mismanagement and loss of trust and confidence, which was approved by the NEA Administrator. Dela Peña later tendered his resignation but subsequently filed a complaint for illegal dismissal before the NLRC, alleging lack of due process and claiming monetary benefits.
The Labor Arbiter upheld the dismissal. On appeal, the NLRC reversed the Arbiter’s decision. ZAMCELCO then filed this petition for certiorari, arguing that the NLRC lacked jurisdiction as the power to discipline its General Manager rested with its Board and the NEA, and that the dismissal was legal.

ISSUE

Whether the NLRC had jurisdiction over the complaint for illegal dismissal and whether the dismissal of Dela Peña was legal.

RULING

The Supreme Court granted the petition, reversing the NLRC and reinstating the Labor Arbiter’s decision. On jurisdiction, the Court ruled that the dismissal arose from a labor dispute—a termination dispute—which falls under the original and exclusive jurisdiction of the Labor Arbiter and the NLRC pursuant to Article 217 of the Labor Code. Moreover, the Court held that ZAMCELCO was estopped from questioning the NLRC’s jurisdiction, as it actively participated in the proceedings before the Labor Arbiter and the NLRC without raising the issue until an adverse resolution was rendered.
On the merits, the Court found the dismissal legal. Dela Peña, as General Manager, held a position of utmost trust and confidence. Loss of trust and confidence is a valid ground for dismissal under the Labor Code. The record showed that ZAMCELCO and the NEA conducted a thorough investigation through a committee and multiple audit teams over nearly a year, giving Dela Peña ample opportunity to answer the charges. The Board’s termination resolution, based on specific findings of mismanagement and loss of trust, was duly approved by the NEA. The dismissal was for cause and executed in good faith, complying with procedural due process. Consequently, Dela Peña was not entitled to moral damages or other monetary claims.