GR 156766; (April, 2009) (Digest)
G.R. No. 156766; April 16, 2009
ROSARIO A. GATUS, Petitioner, vs. QUALITY HOUSE, INC. and CHRISTOPHER CHUA, Respondents.
FACTS
Petitioner Rosario A. Gatus was employed as an assembler by respondent Quality House, Inc. starting July 14, 1987. On June 30, 1997, an incident occurred where petitioner’s husband, Ferdinand Gatus, mauled her co-employee and supervisor, Leonilo Echavez, at a waiting shed near the company premises. Witness affidavits stated that petitioner instigated her husband by urging “Sige pa! sige pa!” during the assault. The respondent company placed petitioner under preventive suspension from July 1 to July 8, 1997, pending investigation. Petitioner submitted an explanation claiming she was being harassed at work due to her union activities. On July 7, 1997, she filed a complaint for illegal suspension. On July 9, 1997, the company terminated her employment via a memorandum. She amended her complaint to include illegal dismissal and unfair labor practice. The Labor Arbiter dismissed her complaint, finding the mauling was work-related and instigated by petitioner, constituting a just cause for dismissal under Article 282 of the Labor Code. The NLRC initially affirmed this but, upon motion for reconsideration, reversed itself and ordered her reinstatement with backwages. The Court of Appeals, reviewing the facts, reversed the NLRC’s reconsidered decision, reinstating the Labor Arbiter’s ruling. The CA denied petitioner’s motion for reconsideration.
ISSUE
Whether the Court of Appeals erred in reversing the NLRC’s decision and in finding that petitioner’s dismissal was for a just and valid cause.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ Decision and Resolution. The Court held that the factual findings of the Court of Appeals, which affirmed the Labor Arbiter’s findings, are conclusive and supported by substantial evidence. The Court found that petitioner’s act of instigating her husband to assault her supervisor constitutes serious misconduct and willful disobedience under Article 282 of the Labor Code, which are just causes for termination. The assault was work-related as it stemmed from workplace conflicts and occurred adjacent to company premises. The Court also noted petitioner’s history of poor work attitude and previous infractions. The Court further ruled that the procedural requirement of a hearing prior to dismissal was substantially complied with, as petitioner was given the opportunity to explain via the preventive suspension notice and her written explanation. The employer’s investigation need not be a formal hearing. The Court emphasized that while social justice principles favor labor, they cannot be used to shield an employee who commits serious misconduct.