G.R. No. 190303 , July 9, 2014
Colegio de San Juan de Letran-Calamba, Petitioner, vs. Engr. Deborah P. Tardeo, Respondent.

FACTS

Petitioner Colegio de San Juan de Letran-Calamba is an educational institution. Respondent Engr. Deborah P. Tardeo was a full-time faculty member since 1985 and was the elected Union President of the Letran-Calamba Faculty and Employees Association (LECFEA). In March 2008, respondent requested fund assistance of ₱17,000.00 from petitioner to attend the 30th National Physics Seminar Workshop Convention. She attached to her request a two-page invitation downloaded from the Philippine Physics Society (PPS) website. During pre-audit, the Vice-President for Finance, Rodolfo Ondevilla, discovered that portions of the downloaded invitation were omitted. The missing portion indicated that the ₱1,200.00 registration fee already covered the seminar kit, among other items. Respondent had separately requested ₱600.00 for a workshop kit. Ondevilla also noted that another faculty member requested only ₱11,000.00 for the same convention. Petitioner’s Committee of Discipline investigated respondent for dishonesty and serious misconduct. Respondent defended herself, stating she omitted parts of the invitation in good faith as they were not applicable to her. The Committee found her guilty and suspended her for one semester. Respondent filed a Complaint for Illegal Suspension with the Office of the Voluntary Arbitrator, which ruled the suspension illegal, finding no direct evidence of malicious alteration. The Court of Appeals affirmed this decision.

ISSUE

1. Whether or not respondent committed dishonesty and serious misconduct in knowingly submitting a materially altered document to support her funding request.
2. Whether or not petitioner respected and observed respondent’s right to due process before deciding to suspend her from work.
3. Whether or not the decision to award damages to respondent without giving petitioner the chance to be heard violated the latter’s right to due process.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Decision and Resolution of the Court of Appeals.
1. Respondent did not commit serious misconduct. Misconduct must be serious, relate to duty performance, and show the employee’s unfitness to continue working. The Court found no substantial evidence that respondent’s omission of portions of the PPS invitation was done with wrongful intent or malice. The Voluntary Arbitrator and the Court of Appeals correctly found that the act, done by an employee with 23 years of untainted service, did not constitute serious misconduct warranting suspension.
2. The Court did not explicitly rule on the procedural due process issue for the suspension, as its finding that no serious misconduct occurred rendered the suspension unlawful regardless of procedure.
3. The Court found no violation of petitioner’s due process rights regarding the award of damages, as the petition’s merits were addressed based on the substantive findings of the lower bodies. The factual findings of the Court of Appeals, affirming those of the Voluntary Arbitrator, are conclusive and binding, especially as they pertain to specialized quasi-judicial bodies.