G.R. No. 124166 November 16, 1999
BENGUET CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and FELIZARDO A. GUIANAN, respondents.

FACTS

Private respondent Felizardo Guianan was a long-time employee of Benguet Corporation, having served since 1963 and eventually rising to Manager of the Materials Group at its Masinloc Chromite Operation. In June 1983, the company received an anonymous letter alleging graft and corruption at the site, implicating Guianan but admitting a lack of proof. Benguet formed an audit committee and, based on initial findings of irregularities involving spare parts, preventively suspended Guianan. By a letter dated August 5, 1983, he was terminated effective August 7, 1983, for breach of trust due to alleged gross negligence and misconduct. A formal investigation was conducted only on August 29, 1983, which led to a second notice of dismissal on November 9, 1983. A criminal complaint for estafa filed by the company was later dismissed after preliminary investigation.
Guianan filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, finding the dismissal illegal due to lack of due process and bad faith, and awarded back wages, separation pay, and damages. The NLRC affirmed the illegality of dismissal but deleted the awards for moral and exemplary damages and attorney’s fees. Benguet Corporation elevated the case to the Supreme Court via certiorari, arguing the NLRC disregarded its evidence.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the finding that Felizardo Guianan was illegally dismissed.

RULING

The Supreme Court dismissed the petition and affirmed the NLRC decision. The Court emphasized that factual findings of quasi-judicial agencies like the NLRC, when supported by substantial evidence, are accorded respect and finality. The legal logic centered on the violation of due process and the absence of a valid just cause for termination.
On due process, the Court found that Guianan was dismissed on August 7, 1983, based merely on an anonymous letter, without being given any prior opportunity to answer the charges. The investigation committee was constituted only twenty-two days after this termination, making it a mere afterthought designed to cure the procedural defect of the initial dismissal. This sequence demonstrated a lack of good faith and compliance with the mandatory twin-notice requirement.
On the existence of a just cause, the Court upheld the Labor Arbiter’s finding that the alleged gross negligence and breach of trust were not substantiated. The evidence failed to prove Guianan’s personal responsibility for the purchase of defective spare parts, as his role was limited to requisitioning items based on end-user department requests. The company’s failure to substantiate its accusations, coupled with Guianan’s long and unblemished service record, negated the claim of loss of trust and confidence. Consequently, the dismissal was illegal. Given that the dismissal occurred in 1983, prior to the effectivity of Republic Act No. 6715 , back wages were correctly limited to three years. Reinstatement was deemed infeasible due to Guianan’s age, warranting an award of separation pay in lieu thereof.