GR 172306; (September, 2008) (Digest)
G.R. No. 172306. September 29, 2008.
MICHAEL V. SANTOS, Petitioner, versus SHING HUNG PLASTICS, CO., INC. and NATIONAL LABOR RELATIONS COMMISSION, Respondents.
FACTS
Petitioner Michael V. Santos was hired as an administrative assistant by respondent Shing Hung Plastics Co., Inc., with duties including purchasing equipment and supplies. On April 3, 2002, the corporation dismissed him for alleged “money involvement with suppliers.” The corporation claimed that in transactions with JPN, Inc., Santos submitted only acknowledgment letters instead of official receipts and misrepresented prices. Regarding a rental transaction with Roos Industrial Construction, Inc., the corporation presented an affidavit from Roos’ manager, Oscar Deiparine, stating that Santos solicited and received a P5,000 commission.
Santos filed a complaint for illegal dismissal. He explained that the JPN purchases were urgent and cheaper, and the Roos transaction was done upon his superiors’ instructions, denying any commission. The Labor Arbiter ruled in his favor, declaring the dismissal illegal and ordering reinstatement with full backwages and damages.
ISSUE
Was Santos dismissed for a just cause?
RULING
Yes, the Supreme Court upheld the dismissal for loss of trust and confidence, a just cause under Article 282(c) of the Labor Code. The legal logic requires that the employee holds a position of trust, the act constituting breach of trust is work-related, and the employer presents substantial evidence of the breach. Santos, as a purchasing assistant regularly handling significant corporate funds and property, undeniably occupied a position of trust.
The Court found the corporation presented substantial evidence. For the JPN transactions, it submitted audit results and certification letters showing irregularities, and evidence disproving Santos’ claim of lower prices. For the Roos transaction, Deiparine’s detailed affidavit attested to the solicitation and collection of the commission, corroborated by a gate pass showing Santos’ absence for a purported errand on the collection date. These specific acts, directly related to his fiduciary duties, constituted a clear breach justifying loss of confidence. The dismissal was for a just cause, though procedural due process was not followed, warranting only an award of nominal damages.