GR 174593; (August, 2010) (Digest)
G.R. No. 174593 ; August 25, 2010
Alex Gurango, Petitioner, vs. Best Chemicals and Plastics Inc. and Moon Pyo Hong, Respondents.
FACTS
Petitioner Alex Gurango, a boiler operator for respondent Best Chemicals and Plastics Inc. (BCPI), was involved in an incident on May 5, 2003, with security guard Romeo Albao. BCPI had a memo prohibiting personal items at workstations. Gurango alleged that while performing his duties with a camera (without film), Albao accosted him, attempted to confiscate the camera, and, together with another guard, assaulted him. A co-worker, Elvin Juanitas, corroborated Gurango’s account in a written statement, detailing the unprovoked attack and Gurango’s refusal to fight back. Gurango sustained injuries requiring medical treatment.
Respondents presented a contradictory version from Albao, claiming Gurango attempted to enter a restricted area with the camera, became aggressive, tried to grab Albao’s gun, and initiated a fistfight. BCPI placed Gurango under preventive suspension and later terminated his employment for serious misconduct and willful disobedience. Gurango filed a complaint for illegal dismissal.
ISSUE
Whether the Court of Appeals erred in reversing the factual findings of the Labor Arbiter and the National Labor Relations Commission (NLRC), which ruled in favor of Gurango and declared his dismissal illegal.
RULING
The Supreme Court granted the petition and reinstated the NLRC’s resolutions. The Court emphasized the well-established doctrine that factual findings of labor tribunals, when supported by substantial evidence, are accorded respect and finality. These quasi-judicial bodies possess expertise in their jurisdiction, and their assessments on witness credibility are binding absent a showing of arbitrariness.
The Labor Arbiter and NLRC found Gurango’s narrative, corroborated by Juanitas’s detailed letter and a medical report, more credible than Albao’s uncorroborated claim. They noted inconsistencies in Albao’s statement and found no evidence that Gurango violated company rules or initiated violence. The camera had no film, and Gurango was performing his duties. The preventive suspension and subsequent dismissal were therefore unjustified. The Court of Appeals’ reversal was baseless, as it improperly re-evaluated evidence and overturned credibility determinations already settled by the specialized agencies. Consequently, the dismissal was illegal for lack of just cause.