G.R. No. 162468 ; January 23, 2007
AMA COMPUTER COLLEGE, INC., AMABLE R. AGUILUZ V, and CARMELITA R. CONDENUEVO, Petitioners, vs. ZENAIDA R. GARAY, Respondent.

FACTS

Petitioner AMA Computer College, Inc. (AMACC) employed respondent Zenaida R. Garay as a College Instructor in 1994, promoting her to High School Principal on May 13, 1996. On May 17, 1996, the school cashier, Sarah Pechardo, inadvertently left an envelope containing P47,299.34 in a comfort room. Upon realizing her loss, Pechardo reported that Garay was the only person she recalled entering the comfort room after her. Petitioners immediately investigated Garay, subjecting her to physical inspection and a search of her office, but found nothing. The incident was recorded in the barangay blotter.
Garay was preventively suspended on May 20, 1996. Petitioners served her with notices for hearings and written explanations, which she complied with, but the scheduled hearings were repeatedly cancelled. On June 19, 1996, petitioners terminated Garay’s employment effective the next day on the ground of loss of trust and confidence. This notice was set aside, and a new hearing was set for June 27, 1996, which was also cancelled. On July 1, 1996, petitioners finally terminated Garay’s employment on the same ground. Garay subsequently filed a complaint for illegal dismissal.

ISSUE

Whether the Court of Appeals committed reversible error in affirming the findings of the Labor Arbiter and the NLRC that Garay’s dismissal was illegal due to lack of substantial evidence for loss of trust and confidence.

RULING

The Supreme Court denied the petition and affirmed the assailed Court of Appeals decision. The core legal principle is that factual findings of quasi-judicial bodies like the NLRC, when affirmed by the Court of Appeals and supported by substantial evidence, are generally conclusive and binding upon the Court. The petitioners were essentially raising a question of fact, which is beyond the scope of a petition for review under Rule 45.
On the substantive issue, the Court held that for a dismissal based on loss of trust and confidence to be valid, it must rest on a willful breach of trust founded on clearly established facts. The burden of proof lies with the employer. The records reveal a fatal shift in the petitioners’ position: Garay was initially investigated as the primary suspect for the missing money. When no evidence connected her to the loss, the charge was altered to allege a belligerent and uncooperative attitude during the investigation. The Court found this shift indicative of a baseless accusation from the outset.
The evidence showed Garay complied with the written notices and participated in the investigation. Any exasperation she expressed did not constitute a willful breach justifying loss of trust. Consequently, petitioners failed to discharge their burden of proving a valid and legal cause for dismissal. The termination was therefore declared illegal for lack of just cause, warranting reinstatement and payment of backwages and damages.