GR 116692; (March, 1997) (Digest)
G.R. No. 116692 March 21, 1997
SAMAR II ELECTRIC COOPERATIVE INCORPORATED, represented by PONCIANO R. ROSALES, General Manager, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION and FROILAN RAQUIZA, respondents.
FACTS
Private respondent Froilan Raquiza was a regular employee of petitioner Samar II Electric Cooperative, Inc. (SAMELCO II). On January 21, 1988, a major breakdown of a pielstick engine occurred during his shift, causing a four-month power failure. After investigation, SAMELCO II found Raquiza and two co-employees guilty of gross negligence. Raquiza was placed under preventive suspension and subsequently terminated on February 29, 1988.
Raquiza filed a complaint for illegal dismissal in December 1988. The Labor Arbiter ruled the dismissal was for a just cause. On appeal, the National Labor Relations Commission (NLRC) reversed the decision, declaring the dismissal illegal. It ordered reinstatement with full backwages not exceeding three years or separation pay, plus attorney’s fees. SAMELCO II’s motion for reconsideration was denied, prompting this petition for certiorari alleging grave abuse of discretion by the NLRC.
ISSUE
Whether the NLRC committed grave abuse of discretion in reversing the Labor Arbiter and declaring Raquiza’s dismissal illegal.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the NLRC. The Court emphasized that technical rules of evidence are not strictly applied in labor proceedings, as mandated by Article 221 of the Labor Code and the NLRC Rules of Procedure. Consequently, Raquiza’s failure to specifically deny the charges against him during the proceedings was not fatal to his claim.
The Court upheld the NLRC’s finding that petitioner failed to discharge its burden of proving that the dismissal was for a just cause. The alleged gross negligence was not sufficiently established. The NLRC correctly noted evidence, including a consultant’s report, indicating the engine breakdown was likely due to worn-out spare parts and operation beyond recommended hours, not solely to Raquiza’s negligence. Furthermore, the Court found discriminatory treatment, as Raquiza was dismissed while his two co-employees found similarly liable were only suspended. The employer’s prerogative to dismiss must be exercised in good faith and supported by substantial evidence, which was lacking in this case.