G.R. No. 100749 April 24, 1992
GT PRINTERS and/or TRINIDAD G. BARBA, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION (4TH DIVISION) and EDWIN RICARDO, respondents.

FACTS

The private respondent, Edwin Ricardo, was employed by GT Printers, owned by Trinidad Barba, starting as an apprentice in 1968. He was promoted to production manager and later to general manager in 1978, receiving a monthly basic salary, ECOLA, representation allowance, and a 3% share in gross receipts. In February 1985, Ricardo’s wife established Insta Printers, a rival printing press, with Ricardo as consultant and owner. Subsequently, Ricardo became a habitual absentee at GT Printers, neglected his duties, and caused major printing errors and rejected job orders. He used GT Printers’ materials for Insta Printers, instructed staff to prioritize Insta Printers’ orders, pirated GT Printers’ customers, and manipulated price quotations to favor his own business. Due to these irregularities, GT Printers suspended Ricardo for 30 days and replaced him with Richard Barba effective June 18, 1986. Ricardo was notified of investigations scheduled on July 24, 1986, and August 13, 1986, but he did not appear. He stopped reporting for work and filed a complaint for illegal dismissal. The Labor Arbiter found the dismissal lawful but awarded separation pay. The NLRC reversed this, finding the dismissal illegal and ordering reinstatement with backwages and separation pay. GT Printers filed this petition.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in reversing the Labor Arbiter’s decision and finding that Edwin Ricardo was illegally dismissed without just cause and due process.

RULING

The Supreme Court granted the petition and reversed the NLRC decision. The Court held that the twin requirements for a valid termination—due process and just cause—were substantially met. Ricardo was given ample opportunity to be heard at two scheduled investigations but chose not to attend. Due process only requires an opportunity to be heard, not necessarily a hearing. The evidence of Ricardo’s dishonesty, disloyalty, breach of trust, and neglect of duties stood uncontroverted. As a managerial employee, his actions constituted willful breach of trust and loss of confidence, which are valid grounds for dismissal. The employer has the right to dismiss an employee whose continuance in service is inimical to its interests. Reinstatement is not appropriate for erring managers. Therefore, Ricardo’s dismissal was lawful, and his complaint for illegal dismissal was dismissed for lack of merit.