G.R. No. 149433; December 15, 2010
The Coca-Cola Export Corporation, Petitioner, vs. Clarita P. Gacayan, Respondent.

FACTS

Petitioner Coca-Cola Export Corporation terminated respondent Clarita P. Gacayan, a Senior Financial Accountant, for loss of trust and confidence. The dismissal stemmed from her submission of three altered receipts to support claims for meal expense reimbursement under company policy. The first, a McDonald’s receipt, had an altered date. The second and third, from Shakey’s, contained handwritten changes to the food items ordered and an annotation about a 50% payment, respectively. The company conducted an investigation, requiring Gacayan to explain each discrepancy. Her explanations varied, attributing the alterations to restaurant staff, her sister’s driver, or claiming she instructed the delivery staff to make corrections for accuracy, denying any fraudulent intent.
The Labor Arbiter ruled the dismissal illegal, a decision reversed by the NLRC, which found just cause for termination. The Court of Appeals reinstated the Labor Arbiter’s decision, ordering Gacayan’s reinstatement with full backwages. It found the evidence of fraud insufficient and held that the alleged infractions, involving small amounts, were too trivial to warrant dismissal of a managerial employee with a long, unblemished record. Coca-Cola elevated the case to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC and ruling that respondent’s dismissal was illegal.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and affirming the NLRC’s finding of a valid dismissal. The legal logic rests on the nature of Gacayan’s position and the established facts. As a Senior Financial Accountant, she held a position of paramount trust, responsible for handling company finances. Loss of trust and confidence is a valid ground for dismissing such an employee. The employer’s burden is to prove by substantial evidence that the act justifying the loss of confidence was committed.
The Court found this burden satisfied. The alterations on the official receipts were undeniable and material. Gacayan’s shifting and inconsistent explanations—first blaming others, then admitting she asked for an alteration on one receipt—undermined her credibility and demonstrated a lack of candor. Fraud in expense claims, regardless of the amount, is a serious breach of trust for a financial officer. The Court emphasized that the amount involved is inconsequential; the act itself corrodes the trust essential to an employment relationship grounded on confidence. The company followed due process by conducting a thorough investigation with notice and hearing. Consequently, the dismissal for loss of trust and confidence was justified.