G.R. No. 209735, July 17, 2019
Stanfilco – A Division of Dole Philippines, Inc. and Reynaldo Casino, Petitioners, vs. Jose Tequillo and/or National Labor Relations Commission – Eighth Division, Respondents.

FACTS

Petitioner Stanfilco terminated respondent Jose Tequillo, a Farm Associate, for serious misconduct. The charges stemmed from an incident on September 12, 2009, where Tequillo, instead of attending a mandatory company-initiated “Kaibigan Fellowship,” engaged in a drinking spree within company premises with co-workers. During this gathering, Tequillo expressed resentment over not receiving a performance incentive. When co-worker Resel Gayon, who had joined them, suggested he air his grievances to management, Tequillo mauled Gayon.
Following administrative proceedings, the Labor Arbiter (LA) upheld the dismissal, ruling the acts constituted serious misconduct and willful disobedience. The National Labor Relations Commission (NLRC) reversed the LA, declaring the dismissal illegal. The NLRC found the mauling was not work-related as Tequillo was not performing official duties at the time. The Court of Appeals (CA) affirmed the NLRC, holding the act amounted only to simple misconduct.

ISSUE

Whether the CA erred in affirming the NLRC’s finding that Tequillo was illegally dismissed.

RULING

The Supreme Court granted the petition, reversing the CA and NLRC and reinstating the LA’s decision. The Court held that Tequillo’s dismissal for serious misconduct was valid. The legal logic centered on establishing the work-connection of the misconduct. The Court clarified that an act need not occur during the performance of specific duties to be work-related; it is sufficient that it transpired within company premises during work hours and is connected to the employee’s work.
Here, the “Kaibigan Fellowship” was a mandatory, company-initiated activity integral to operations, used for announcements and updates. Tequillo’s absence to instead drink alcohol on company property constituted willful disobedience. The subsequent mauling of a co-worker directly arose from a work-related grievance concerning performance incentives. This violent act, coupled with the drinking, displayed a character antithetical to and incompatible with continued employment. The employer satisfactorily proved a reasonable connection between Tequillo’s offenses and his duties, rendering him unfit for further service. Thus, the dismissal was for a just cause under Article 296 (formerly 282) of the Labor Code. The NLRC and CA committed grave abuse of discretion in ignoring these established facts.