GR 183196; (August, 2009) (Digest)
G.R. No. 183196; August 19, 2009
CHONA ESTACIO and LEOPOLDO MANLICLIC, Petitioners, vs. PAMPANGA I ELECTRIC COOPERATIVE, INC., and LOLIANO E. ALLAS, Respondents.
FACTS
Petitioners Chona Estacio and Leopoldo Manliclic were employees of respondent Pampanga I Electric Cooperative, Inc. (PELCO I). An internal audit revealed Estacio, a bill custodian, had unremitted bills amounting to ₱123,807.14 under her accountability. She explained she had no control over collectors’ remittances and that flooding caused delays in updating records. Manliclic, a bill collector, admitted in his written explanation that he used ₱4,813.11 from his collections for family obligations and requested time to repay. After separate investigations, both were dismissed for gross negligence and misappropriation of company funds, respectively.
The Labor Arbiter dismissed their complaint for illegal dismissal. The National Labor Relations Commission (NLRC) reversed, finding illegal dismissal and ordering reinstatement with backwages. The Court of Appeals then annulled the NLRC decision, reinstating the Labor Arbiter’s ruling. The CA held that the NLRC committed grave abuse of discretion, as the dismissals were for just causes and due process was observed.
ISSUE
Whether the Court of Appeals erred in ruling that petitioners were validly dismissed from employment.
RULING
No, the Court of Appeals did not err. The Supreme Court affirmed the CA decision, upholding the validity of the dismissals. For Estacio, the Court found her negligence was gross. As bill custodian, her primary duty was to safeguard and account for bills and collections. The audit finding of numerous unremitted bills under her watch constituted a breach of this fundamental duty, which amounted to gross neglect under Article 282(b) of the Labor Code. Her excuses of flooding and lack of control over collectors were insufficient, as safeguarding the bills was her direct responsibility.
For Manliclic, his admission of misusing collected funds established just cause for dismissal under Article 282(c) for willful breach of trust. Employees charged with custody and handling of company funds occupy positions of trust. His act of lending collections to a co-employee constituted a clear misappropriation and a fundamental breach of that trust. The Court emphasized that loss of confidence as a ground for dismissal does not require proof beyond reasonable doubt but only substantial evidence, which his own written admission amply provided. Due process was also satisfied as both petitioners were given notice, opportunity to explain, and a hearing.