G.R. No. 148105 ; July 22, 2004
FRANCISCO REYNO, petitioner, vs. MANILA ELECTRIC COMPANY, respondent.

FACTS

Petitioner Francisco Reyno was employed by respondent Manila Electric Company (MERALCO) as an Assistant Squad Leader in the Inspection Department. His duties included inspecting electric meters, ensuring accurate consumption records, and reporting customers who used illegal devices to reduce their bills. MERALCO implemented an incentive scheme granting additional overtime pay for every report of a major violation. In July 1987, an investigation by MERALCO’s Special Presidential Committee (SPC) into an illegal connection at a restaurant led to statements from Reyno’s own squad members. They alleged that Reyno had instructed them to fabricate inspection reports, such as falsely reporting jumper wires, underreporting violations, and failing to recommend laboratory tests for tampered meters, with one violation involving a personal acquaintance.
The SPC conducted clarificatory hearings. Reyno’s counsel failed to appear at the scheduled hearings, and Reyno opted to proceed without counsel. After evaluation, the SPC found Reyno guilty of dishonesty, serious misconduct, and willful breach of trust. MERALCO terminated his employment. Reyno filed a complaint for illegal dismissal, arguing he was denied due process and that his long service should mitigate the penalty.

ISSUE

Whether the dismissal of Francisco Reyno was valid based on just causes and with due process.

RULING

The Supreme Court upheld the validity of Reyno’s dismissal. On procedural due process, the Court found Reyno was afforded ample opportunity to be heard. He was informed of the charges, participated in the investigation, and was allowed to submit counter-affidavits and request a re-investigation. His counsel’s failure to appear did not negate the process, as he chose to proceed. On substantive grounds, the affidavits of his subordinates constituted substantial evidence proving he committed acts of dishonesty and serious misconduct by fabricating reports, which directly violated his duty of safeguarding company interests. As a supervisory employee tasked with preventing fraud, his actions constituted a willful breach of the trust reposed in him by MERALCO. The Court emphasized that length of service aggravates, rather than mitigates, the offense for a long-standing employee who is expected to be more loyal and familiar with company norms. Therefore, the dismissal for just causes under Article 282 of the Labor Code was legal.