G.R. No. 177647 October 31, 2008
U-BIX CORPORATION and EDILBERTO B. BRAVO, petitioners, vs. VALERIE ANNE H. HOLLERO, respondent.

FACTS

Petitioner U-Bix Corporation hired respondent Valerie Anne H. Hollero as a management trainee on March 6, 1996, later promoting her to facilities manager. U-Bix sent respondent to the United States for two months of training for a newly acquired franchise. Before leaving, she signed a contract requiring her to remain in the company’s employ for five years after training completion, otherwise she would reimburse the training costs. On February 14, 1997, U-Bix terminated respondent’s employment for alleged “pattern of tardiness, absences, neglect of duties, and lack of interest.” U-Bix filed a complaint for reimbursement of training expenses. Subsequently, respondent filed a complaint for illegal dismissal. The cases were consolidated. The Labor Arbiter found the dismissal valid and ordered respondent to reimburse training expenses. The NLRC reversed the decision, finding the dismissal illegal and awarding backwages and separation pay, while dismissing U-Bix’s complaint for lack of jurisdiction. The Court of Appeals affirmed the NLRC with a clarification that U-Bix’s complaint was dismissed for lack of merit.

ISSUE

1. Whether petitioners established a valid cause for respondent’s dismissal.
2. Whether petitioner U-Bix observed the procedural requirements of due process in terminating respondent.
3. Whether petitioner U-Bix is entitled to reimbursement of respondent’s training expenses.

RULING

1. No. Petitioners failed to substantiate their allegations of habitual absenteeism, tardiness, neglect of duties, and lack of interest. They presented no daily time records, attendance records, or other documentary evidence. Respondent’s Pay Advice Slips showed no deductions for absences or tardiness except for a duly approved leave. A memorandum from her superior close to her termination praised her critical role, belied the allegations of poor performance, and a receipt substantiated her account of being asked to turn over keys on December 23, 1996, contradicting the claim of abandonment. The employer bears the burden of proof in termination cases, and this burden was not met.
2. No. The Court of Appeals correctly ruled that U-Bix failed to observe due process. The termination letter did not specify the grounds for dismissal with particularity, as it merely stated a “pattern of tardiness, absences, neglect of duties, and lack of interest” without detailing the facts. Furthermore, the required twin notices were not properly given. The memorandum asking for an explanation was handcarried to her only after she had already been asked to turn over her keys and files on December 23, 1996, and she was not given a real opportunity to be heard.
3. No. The claim for reimbursement of training expenses based on the training contract is a money claim arising from an employer-employee relationship, but it does not involve a claim under the Labor Code, other labor statutes, or a collective bargaining agreement. Therefore, it falls outside the jurisdiction of the Labor Arbiter and the NLRC. The original complaint for reimbursement should have been dismissed for lack of jurisdiction.
The Supreme Court AFFIRMED the Court of Appeals Decision with MODIFICATION, clarifying that NLRC-NCR Case No. 00-05-03696-97 (the reimbursement complaint) is dismissed for lack of jurisdiction.