G.R. No. 192826; February 27, 2013
PHILIPPINE PLAZA HOLDINGS, INC., Petitioner, vs. MA. FLORA M. EPISCOPE, Respondent.

FACTS

Petitioner Philippine Plaza Holdings, Inc. (PPHI), owner of Westin Philippine Plaza Hotel, terminated respondent Ma. Flora M. Episcope, a long-time employee, for dishonesty, willful disobedience, and serious misconduct. The dismissal stemmed from an incident on August 28, 2004, where Sycip, Gorres and Velayo auditors dined at the hotel’s Café Plaza. Episcope attended to them, presented a check for ₱2,306.65, received payment of ₱2,400, and returned the stamped “paid” check with change. An internal audit later revealed a discrepancy: the hotel’s copy of the receipt showed a ₱906.45 discount using a Starwood Privilege Card registered to a Peter Pamintuan, while the receipt given to the auditors reflected the full amount. Consequently, the hotel remitted only ₱1,400.20, creating a shortage.
During administrative proceedings, Episcope admitted being on duty but could not recall if a discount card was presented. She denied stamping the check “paid” or applying a discount without a card, shifting responsibility to the cashier. The cashier, however, asserted that a discount slip and stamped receipt indicated a card was presented. PPHI found her explanations insufficient and terminated her employment. Episcope filed an illegal dismissal complaint.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC and finding Episcope’s dismissal illegal.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the NLRC’s decision which upheld the dismissal. The legal logic centers on the standard of review and the sufficiency of evidence for dismissal based on loss of trust and confidence. In a Rule 45 petition, the Court’s role is limited to reviewing errors of law, not re-examining factual findings of quasi-judicial agencies like the NLRC, whose expertise on labor matters is respected. The Court found the CA improperly substituted its own judgment for that of the NLRC, which had affirmed the Labor Arbiter’s factual conclusion.
Substantially, the Court held that the evidence—the audit report, discount slip, stamped receipt, cashier’s statement, and Episcope’s own admissions during the hearing—constituted substantial evidence to support the finding of dishonesty. As an employee handling cash transactions, Episcope held a position of trust. Her failure to adequately explain the unauthorized discount application, which caused financial loss to the hotel, justified her dismissal for breach of trust. The dismissal was therefore legal, having both a valid cause and observance of procedural due process through the show-cause memo and hearing. Her monetary claims were also denied for lack of substantiation.