G.R. No. 119509 February 11, 1999
ENRIQUE A. ARBOLEDA, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and MANILA ELECTRIC COMPANY, respondents.

FACTS

Petitioner Enrique A. Arboleda was an employee of Manila Electric Company (MERALCO) for twenty-five years until his dismissal on February 11, 1988. He was dismissed under the company’s Code of Employee Discipline for misappropriating or withholding company funds. The case stemmed from an incident involving Antonio D. Sy, who applied for electrical service. Sy was found to have illegal electrical connections on March 6, 1987, and June 8, 1987. Sy testified that on June 9, 1987, he went to the MERALCO Novaliches office to pay his Found Connection (FC) bills and met Arboleda, who told him he had to pay around P2,000.00. Sy gave Arboleda P1,200.00, which Arboleda received without issuing an official receipt. Arboleda later sent individuals to install a meter. Marcelo P. Umali, the branch manager, discovered Sy’s illegal connection on June 16, 1987, and Sy protested that he had paid Arboleda. Sy settled his FC bills with MERALCO and was issued an official receipt. An investigation was conducted against Arboleda, who made a general denial of knowing Sy or the individuals involved. The Labor Arbiter sustained Arboleda, finding illegal dismissal on grounds that Sy’s accusation was prompted by Umali, Sy’s credibility was suspect due to his illegal connections, and Sy’s motive was malicious. The NLRC reversed the Labor Arbiter’s decision, finding no proof of instigation by Umali, crediting Sy’s testimony, and dismissing exculpating evidence as a ruse.

ISSUE

The main issue is the legality of petitioner’s dismissal, which hinges on whether he was afforded due process and whether the dismissal was for a valid cause as provided under Article 282 of the Labor Code.

RULING

The Supreme Court dismissed the petition and affirmed the decision of the NLRC. The Court held that MERALCO substantially complied with the due process requirements by furnishing Arboleda with two written notices: one on October 21, 1987, notifying him of the charges and his right to representation, and another on February 11, 1988, notifying him of his dismissal and the reasons thereof. The Court found that the essence of due process—an opportunity to be heard—was met, and full adversarial proceedings are not necessary unless requested for clarification. On the substantive aspect, the Court ruled that MERALCO discharged its burden of proving a valid cause for dismissal. The Court credited the testimony of Antonio Sy as categorical, spontaneous, and credible, finding it replete with consistent details and lacking any ulterior motive to fabricate. The Court noted that Sy’s testimony was positive and entitled to greater weight than Arboleda’s general denial. The Court also found that substantial evidence—such relevant evidence as a reasonable mind might accept as adequate—supported the conclusion of misappropriation. The NLRC’s factual findings, which differed from the Labor Arbiter’s, were reviewed and preferred as more conformable to the evidentiary facts. Thus, the dismissal was for a just cause and legally valid.