G.R. No. 202392 . October 04, 2021.
PACIFIC ROYAL BASIC FOODS, INC., PETITIONER, VS. VIOLETA NOCHE, JULIANA L. ABRIGUNDA, CRISANTA A. TALAVERA, MA. ASUNCION A. ARGUELLES, CIRIACA A. VELASCO, SEVERA B. QUITAIN, ROSALINDA BALAHADIA, ANICIA DAGLE, NORMA K. PLATA, ZENAIDA B. BULAHAN AND SUSANA D. AMPARO, RESPONDENTS.

FACTS

Petitioner Pacific Royal Basic Foods, Inc. (PRBFI) employed respondents as coconut parers. On March 14, 2007, respondents filed a complaint for non-regularization with the DOLE. On March 20, 2007, PRBFI sent similarly-worded letters to respondents, citing a product contamination incident and placing them on a 15-day preventive suspension while the matter was being investigated. Some respondents submitted joint replies denying involvement. On April 27, 2007, PRBFI dismissed respondents via termination letters stating the company had lost trust and confidence in them due to their alleged involvement in the contamination, failure to provide a detailed explanation, and lack of cooperation. On April 23, 2007, respondents filed a complaint for illegal dismissal, illegal suspension, regularization, damages, and reinstatement. PRBFI justified the dismissal based on an anonymous letter warning of a plan to sabotage production and claimed respondents were dismissed for just causes (serious misconduct, willful disobedience, fraud/willful breach of trust) after an investigation. The Labor Arbiter ruled for respondents, finding illegal dismissal due to lack of just cause and procedural due process, and declared them regular employees. The NLRC reversed, but the Court of Appeals reinstated the Labor Arbiter’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the Labor Arbiter’s finding that respondents were illegally dismissed.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the CA decision. PRBFI failed to prove by substantial evidence that respondents committed the alleged infractions justifying dismissal. The anonymous letter was hearsay and insufficient to establish wrongdoing. The charges of serious misconduct, willful disobedience, and loss of trust and confidence were unsubstantiated. Respondents, as rank-and-file employees, do not hold positions of trust and confidence in the sense required for dismissal on that ground. Furthermore, PRBFI violated procedural due process; the March 20, 2007 letters did not specify the charges with particularity or give respondents a real opportunity to respond, and the termination letters did not indicate that grounds for dismissal had been established. Respondents, having worked for more than one year, were regular employees. They are entitled to reinstatement without loss of seniority rights, full backwages, and other benefits from the date of dismissal until actual reinstatement. The 15-day preventive suspension was also declared illegal, entitling them to payment for that period.