GR 159556; (May, 2005) (Digest)
G.R. No. 159556 May 26, 2005
Philippine Airlines, Inc. vs. Honorable Court of Appeals and Alendry De Leon
FACTS
The case originated from a complaint by passenger Cesar Villanueva, who discovered his unused Manila-Iloilo ticket was fraudulently refunded to another person. An internal audit by Philippine Airlines (PAL) revealed a scheme wherein check-in clerks and load control clerks at Iloilo Airport would not properly log passengers who had actually boarded flights. The unchecked tickets were then forwarded to ticket freight clerks, who would fraudulently reissue, revalidate, and refund the tickets, making it appear the passengers had cancelled. PAL’s investigation, covering July to September 1995, uncovered over 60 such incidents, with passengers confirming they flew and did not seek refunds.
Respondent Alendry De Leon, a Ticket Freight Clerk, was implicated. He was identified as having affixed a revalidation sticker to Villanueva’s fraudulently reissued ticket. PAL charged De Leon with serious misconduct, fraud, and breach of trust. De Leon denied involvement, claiming he merely processed documents given to him. After administrative hearings, PAL found De Leon guilty and dismissed him. The Labor Arbiter and NLRC upheld the dismissal, but the Court of Appeals reversed, finding the evidence against De Leon insufficient.
ISSUE
Whether the Court of Appeals erred in reversing the findings of the NLRC and in ruling that PAL failed to substantiate its charges of serious misconduct and breach of trust against respondent Alendry De Leon.
RULING
Yes, the Supreme Court reversed the Court of Appeals and reinstated the NLRC decision. The legal logic rests on the principle that in termination cases, substantial evidence is sufficient. The Court found that PAL presented substantial evidence proving De Leon’s participation in the fraudulent refund scheme. His specific act of affixing a revalidation sticker to Villanueva’s ticket, which was a critical step in the modus operandi, directly linked him to the anomaly. His defense of merely following orders was untenable, as his job required the exercise of discretion and diligence to prevent fraud.
As a Ticket Freight Clerk, De Leon occupied a fiduciary position requiring utmost trust. His actions constituted willful breach of that trust and serious misconduct, which are valid grounds for dismissal under the Labor Code. The Court emphasized that loss of trust and confidence need only be based on substantial evidence, not proof beyond reasonable doubt. Given the preponderance of evidence showing a coordinated fraud and De Leon’s integral role therein, PAL acted within its management prerogative in terminating his employment for cause.