G.R. No. 114129 October 24, 1996
MANILA ELECTRIC COMPANY, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and JEREMIAS G. CORTEZ, respondents.

FACTS

Private respondent Jeremias Cortez was a regular employee of MERALCO, working as a 1st class lineman-driver. His employment record was marred by a series of disciplinary infractions, primarily involving unauthorized absences and violations of sick leave policies, for which he received multiple suspensions and a final warning. The incident leading to his dismissal involved his failure to report for work from August 2 to September 19, 1989, without prior notice to his superiors. MERALCO conducted an administrative investigation, found him guilty of gross neglect of duty under its company code, and terminated his services effective January 19, 1990.
Cortez filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, upholding the dismissal as a valid exercise of management prerogative due to Cortez’s habitual neglect and serious misconduct. On appeal, the NLRC reversed the Labor Arbiter’s decision, ordering Cortez’s reinstatement with backwages. The NLRC found that Cortez was not afforded due process and that his absences were justified as he went into hiding due to a personal trouble, about which he allegedly informed his office.

ISSUE

Whether the dismissal of Jeremias Cortez by MERALCO was valid, both procedurally and substantively.

RULING

The Supreme Court granted MERALCO’s petition, annulled the NLRC decision, and reinstated the Labor Arbiter’s ruling. The dismissal was valid. Substantively, the Court found just cause for termination. Cortez’s prolonged, unauthorized absence from work constituted gross neglect of duty and willful disobedience under Article 282 of the Labor Code. His extensive record of prior violations demonstrated habitual neglect, and his final excuse of going into hiding was deemed unsubstantiated and insufficient to justify his failure to formally notify the company.
Procedurally, due process was satisfied. Cortez was given the opportunity to explain his side during the company’s administrative investigation. The essence of due process in administrative proceedings is simply an opportunity to be heard, which can be complied with through written explanations or position papers, not necessarily a full adversarial trial. The Court held that MERALCO accorded Cortez this requisite opportunity, and his defense was properly evaluated and found inexcusable. Thus, his dismissal was for a just and authorized cause and effected in accordance with law.