NISSAN MOTORS PHILS., INC., Petitioner, vs. VICTORINO ANGELO, Respondent.
FACTS
Respondent Victorino Angelo was employed by petitioner Nissan Motors Phils., Inc. as a payroll staff on March 11, 1989. On April 7-17, 2000, he was on sick leave and failed to prepare the payroll. He was again on approved vacation leave on April 27-28, 2000, which also resulted in non-preparation of the payroll. On May 8, 2000, he received a memorandum from Nissan informing him that the company was considering his dismissal on grounds of serious misconduct, willful disobedience, and gross neglect of duties. The memorandum detailed a series of incidents: his early departures and absences in April 2000 without proper notice or completion of his payroll tasks, leading to delayed and inaccurate salary releases for employees, causing confusion and anger among the workforce, refusal of workers to render overtime, and operational disruptions for the company. Respondent was placed on preventive suspension and given time to submit a written answer. He filed a complaint for illegal suspension with the DOLE on May 12, 2000. After an investigation on May 13, 2000, Nissan found his explanation insufficient and issued a Notice of Termination on June 13, 2000. Respondent amended his complaint to include illegal dismissal. The Labor Arbiter dismissed the complaint for lack of merit. The NLRC affirmed this decision. The Court of Appeals, however, granted respondent’s petition for certiorari, reversed the NLRC resolutions, and ordered his reinstatement with backwages.
ISSUE
Whether the Court of Appeals erred in reversing the factual findings of the Labor Arbiter and the NLRC and in ruling that respondent was illegally dismissed.
RULING
The Supreme Court granted the petition and reversed the decision of the Court of Appeals. The Court held that the factual findings of the Labor Arbiter and the NLRC, which are supported by substantial evidence, are accorded respect and finality. The Court found that respondent’s actions constituted gross and habitual neglect of duties, a just cause for termination under Article 282(b) of the Labor Code. His failure to perform his critical payroll functions on multiple occasions, despite reminders, and the resulting severe consequences for the company-including operational disruption, financial loss, and employee unrest-demonstrated a want of care and a disregard for the consequences of his actions, amounting to gross negligence. The habitual nature was shown by the repeated incidents. The Court also noted that his actions could likewise be considered serious misconduct or willful disobedience. The employer observed due process by serving two notices and conducting a hearing. Therefore, the dismissal was legal. The award of reinstatement and backwages by the Court of Appeals was set aside.
