G.R. No. 180465; July 31, 2009
ERIC DELA CRUZ and RAUL M. LACUATA, Petitioners, vs. COCA-COLA BOTTLERS PHILS. INC., Respondent.

FACTS

On August 12, 2000, Raymund Sales, a salesman of Coca-Cola Bottlers Phils., Inc., figured in a motor vehicle accident while driving a company vehicle without authorization. The initial police blotter indicated he was under the influence of liquor. Subsequently, petitioners Eric dela Cruz and Raul Lacuata, both sales supervisors, along with another supervisor, were implicated in securing an altered police report and medical certificate dated August 15 and 14, 2000, respectively, which omitted the detail about Sales being intoxicated.
After investigation, respondent company dismissed petitioners for violating the Employees’ Code of Disciplinary Rules, alleging they conspired to produce altered documents to conceal Sales’ condition. Petitioners filed complaints for illegal dismissal. The Labor Arbiter ruled dela Cruz was illegally dismissed but found Lacuata at fault for failing to prevent the alteration, though awarding him back wages and separation pay. The NLRC affirmed but deleted moral damages. The Court of Appeals reversed, finding the dismissals valid.

ISSUE

Whether the Court of Appeals erred in ruling that petitioners were validly dismissed for loss of trust and confidence.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. Petitioners, as supervisory employees, were covered by the trust and confidence rule under Article 282(c) of the Labor Code. For loss of trust to be a valid ground for dismissal, the breach must be willful and work-related. The Court found substantial evidence that petitioners deliberately participated in obtaining altered official documents to cover up a co-employee’s intoxication during a company vehicle accident. This act constituted a willful and deceitful breach of trust directly connected to their duties, as it was inimical to the company’s interests by attempting to obscure facts surrounding a work-related incident. The Court held that the factual findings of the Court of Appeals, which demonstrated petitioners’ active role in the scheme, were supported by the record. Consequently, dismissal was the appropriate penalty, and no award of back wages or separation pay was warranted as the termination was for just cause.