GR 202621; (June, 2016) (Digest)
G.R. No. 202621 June 22, 2016
ZAIDA R. INOCENTE, Petitioner, vs. ST. VINCENT FOUNDATION FOR CHILDREN AND AGING, INC./VERONICA MENGUITO, Respondents.
FACTS
Petitioner Zaida R. Inocente was hired by respondent St. Vincent Foundation, a non-profit organization, in 2000 and promoted to Program Officer in 2001. In 2002, she began a romantic relationship with a co-worker, Marlon D. Inocente. In September 2006, St. Vincent adopted a Non-Fraternization Policy strongly discouraging consensual romantic relationships between employees, particularly those in supervisory roles. Zaida and Marlon discreetly continued their relationship, which remained unknown to the employer even after Marlon resigned in July 2008. In February 2009, Zaida suffered a miscarriage and later underwent surgery for an ectopic pregnancy, informing St. Vincent of her condition.
Upon learning of the relationship through these medical events, St. Vincent charged Zaida with violating the Non-Fraternization Policy and the organization’s Code of Conduct. After she submitted an explanation, St. Vincent terminated her employment on grounds of immorality, gross misconduct, and violation of company policy. Zaida and Marlon subsequently married in June 2009. Zaida then filed a complaint for illegal dismissal.
ISSUE
Whether petitioner Zaida R. Inocente was illegally dismissed.
RULING
Yes, the Supreme Court ruled that Zaida was illegally dismissed. The legal logic centered on the insufficiency of the grounds for termination. First, the Court found that her conduct did not constitute immorality. Immorality implies a conduct so willful, flagrant, and shocking to common moral standards as to be detrimental to the employer’s interests. Zaida’s relationship with Marlon, both unmarried and of legal age without impediment, culminating in marriage, could not be characterized as disgraceful or immoral under prevailing norms. The relationship was private and discreet, and the subsequent marriage negated any claim of immoral character.
Second, the Court held there was no willful breach of trust or serious misconduct. A breach of trust must be founded on willful deceit. Zaida’s failure to disclose the relationship, while a violation of the policy, was not shown to be attended by bad faith or to have caused actual prejudice to the employer’s operations. The policy itself was merely a “strong discouragement,” not an absolute prohibition. Her position as Program Officer did not inherently involve fiduciary duties that were violated by her personal relationship, especially since Marlon was no longer an employee at the time the relationship was discovered. The dismissal failed the twin requirements of substantive and procedural due process, as the cause was not just or authorized. Consequently, she was entitled to reinstatement and full backwages.