G.R. No. 206331, June 04, 2018
DEPARTMENT OF AGRARIAN REFORM MULTI-PURPOSE COOPERATIVE (DARMPC), PETITIONER, VS. CARMENCITA DIAZ, REPRESENTED BY MARY CATHERINE M. DIAZ; EMMA CABIGTING; AND NINA T. SAMANIEGO, RESPONDENTS.

FACTS

Respondents Carmencita Diaz, Emma Cabigting, and Nina Samaniego worked for petitioner Cooperative as Accounting Clerk, Loan Officer and Verifier, and Lending Supervisor, respectively. In October 2003, an anomaly was discovered involving missing receipts and misappropriated share capital payments by Cashier Lorelie Matel and Loan Officer Roslyn Sengson. Matel and Sengson initially implicated the respondents in a conspiracy but later executed sworn retractions stating the respondents were not involved. The Cooperative placed the respondents under preventive suspension and subsequently terminated their employment. The respondents filed a complaint for illegal dismissal.
The Labor Arbiter initially dismissed the complaint, finding the respondents were cooperative members, not employees. The National Labor Relations Commission (NLRC) reversed, finding an employer-employee relationship existed but that dismissal was for a just cause, albeit with a procedural due process violation, awarding nominal damages. The Court of Appeals granted the respondents’ petition for certiorari, finding illegal dismissal and ordering full backwages and separation pay. The Cooperative filed this Petition for Review.

ISSUE

Whether the Court of Appeals erred in finding that the respondents were illegally dismissed.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ ruling. The Court first addressed a procedural matter, noting the Cooperative’s petition failed to state the material dates of receipt of the assailed CA resolutions, a mandatory requirement under Rule 45. While procedural rules may be relaxed for substantive justice, such liberality requires a justifiable reason, which the Cooperative failed to provide. On the merits, the Court upheld the finding of illegal dismissal. The employer bears the burden of proving the validity of dismissal. Here, the sole basis for termination was the alleged admission of receiving a “small token for merienda” from members, which the Cooperative construed as proof of conspiracy in the fund anomaly. The Court agreed with the CA that this act did not constitute substantial evidence of conspiracy or participation in the misappropriation. Mere knowledge or receipt of a token, without intentional participation in the criminal design, is insufficient. The sworn retractions of the principal culprits, Matel and Sengson, completely exonerating the respondents, further demolished the Cooperative’s case. With no lawful cause established, the dismissal was illegal. The awards of backwages and separation pay in lieu of reinstatement were proper.