G.R. No. 187605 , April 13, 2010
Technol Eight Philippines Corporation, Petitioner, vs. National Labor Relations Commission and Dennis Amular, Respondents.

FACTS

Petitioner Technol Eight Philippines Corporation (Technol) hired respondent Dennis Amular in March 1998. On April 16, 2002, after office hours and about 200-300 meters from the workplace, Amular and a co-employee, Clarence Ducay, confronted their team leader, Rafael Mendoza, at an internet café regarding a work-related report. A heated argument ensued, leading to a fistfight stopped by barangay tanods. Technol placed Amular under preventive suspension and required him to explain. An administrative hearing was scheduled, but Amular filed a complaint for illegal suspension/constructive dismissal before the Labor Arbiter and did not attend the hearing. Technol subsequently dismissed Amular for violating company rules, specifically Section 1-k of its HRD Manual penalizing the commission of a crime against a co-employee. The Labor Arbiter ruled the dismissal illegal, citing lack of due process, the incident’s occurrence outside work premises and hours, and a prior settlement among the employees. The NLRC affirmed. The Court of Appeals, while finding the dismissal was for just cause (serious misconduct), still deemed it illegal because the penalty of dismissal was too harsh, as the fight occurred outside company premises after hours, did not disrupt operations, and was “nipped in the bud.”

ISSUE

Whether the Court of Appeals erred in ruling that respondent Dennis Amular was illegally dismissed.

RULING

Yes. The Supreme Court reversed the Court of Appeals and dismissed the complaint for illegal dismissal. The Court held that Amular’s dismissal was for a just cause and that due process was observed. The fistfight constituted serious misconduct. The incident was work-related as it stemmed from a work report, and the participants had a supervisor-subordinate relationship. Company rules can validly cover offenses committed outside the workplace if work-related. The penalty of dismissal was not disproportionate; upholding company discipline is a management prerogative, and the act of mauling a supervisor is grave. Procedural due process was satisfied as Amular was given notices to explain, an opportunity for a hearing (which he chose not to attend by filing a complaint), and a notice of dismissal. The fact that the fight was stopped did not mitigate its seriousness. The prior settlement did not bar the company from imposing discipline. The NLRC’s finding of discrimination was erroneous as evidence showed Ducay was also preventively suspended, and the company had discretion in handling the participants differently.