G.R. No. 165153 September 23, 2008
Carlos C. de Castro, Petitioner, versus Liberty Broadcasting Network, Inc. and Edgardo Quiogue, Respondents.

FACTS

Petitioner Carlos C. de Castro was employed as Building Administrator by respondent Liberty Broadcasting Network, Inc. on August 7, 1995. On May 16, 1996, the respondent company, through its Personnel Manager, served him a notice requiring him to explain within 48 hours alleged violations of the Company Code of Conduct, including serious misconduct, fraud, and willful breach of trust. The charges were based on affidavits from company employees Vicente Niguidula and Gil Balais. The petitioner denied the allegations, claiming they were baseless and orchestrated by respondent Edgardo Quiogue, the Executive Vice President, to protect his favored employees. A formal hearing was scheduled for May 28, 1996, but the petitioner refused to participate after learning that criminal cases for estafa and qualified theft had been filed against him at the Makati Prosecutor’s Office. On May 24, 1996, additional charges were filed based on affidavits from Balais, Cristino Samarita, and Jose Aying. On May 31, 1996, the respondent company issued a Notice of Dismissal citing multiple grounds, including soliciting/receiving money from suppliers, diversion of company funds, theft of company property, disrespect, disorderly behavior, threat and coercion, abuse of authority, and slander.
The petitioner filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, disbelieving the affidavits of the respondents’ witnesses due to prior altercations and recantations. The NLRC initially reversed the Labor Arbiter but, upon motion for reconsideration, reinstated the finding of illegal dismissal, holding the charges were not substantiated beyond the “bare allegations” in the affidavits of witnesses who were company employees with prior conflicts with the petitioner. The Court of Appeals granted the respondent company’s petition for certiorari, reversing the NLRC and validating the dismissal, finding that the NLRC gravely abused its discretion in disregarding the witnesses’ affidavits.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC’s finding that the petitioner was illegally dismissed, specifically in ruling that the NLRC committed grave abuse of discretion and in substituting its own judgment on the factual findings.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals, and REINSTATED the NLRC Resolution dated September 20, 2002. The Court held that the respondent company failed to discharge its burden of proving that the dismissal was for a just or authorized cause. The evidence presented, primarily affidavits from company employees with demonstrated motives against the petitioner, was insufficient to constitute substantial evidence. The affidavits were inconsistent, and key witnesses like Jose Aying had recanted. The NLRC’s factual findings, which coincided with those of the Labor Arbiter, were supported by evidence and thus entitled to respect and finality. The Court of Appeals erred in acting as a trier of facts and in finding grave abuse of discretion where the NLRC’s decision was based on its evaluation of the evidence’s weight and credibility. In labor cases, doubts are resolved in favor of the employee.