GR 211497; (March, 2015) (Digest)
G.R. No. 211497 March 18, 2015
HOCHENG PHILIPPINES CORPORATION, Petitioner, vs. ANTONIO M. FARRALES, Respondent.
FACTS
Respondent Antonio M. Farrales was employed by petitioner Hocheng Philippines Corporation (HPC) on May 12, 1998, eventually promoted to Assistant Unit Chief of Production, a supervisory position. On December 2, 2009, HPC management received a report that an employee’s motorcycle helmet was stolen on November 27, 2009. CCTV footage from November 27, 2009, showed Farrales taking a helmet from a parked motorcycle. HPC sent Farrales a notice to explain. Farrales claimed he borrowed a helmet from co-worker Eric Libutan, who described his helmet and motorcycle. Farrales stated he mistakenly took a different helmet, belonging to Reymar Solas, thinking it was Eric’s, and promptly apologized and arranged for its return upon realizing the error. After a hearing, HPC terminated Farrales on February 15, 2010, for violation of its Code of Discipline (stealing), akin to serious misconduct and willful breach of trust under Article 282 of the Labor Code. Farrales filed a complaint for illegal dismissal. The Labor Arbiter ruled in favor of Farrales, awarding backwages, separation pay, bonuses, damages, and attorney’s fees. The NLRC reversed, finding substantial evidence for just cause. The Court of Appeals reinstated the Labor Arbiter’s decision with modifications, deleting the awards for moral and exemplary damages.
ISSUE
Whether the Court of Appeals erred in reversing the NLRC and declaring the dismissal of Farrales illegal for HPC’s alleged failure to prove the existence of a just cause for termination.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that HPC failed to prove by substantial evidence that Farrales committed theft, which requires a perverse and wrongful intent to gain. The evidence showed Farrales had a prior arrangement to borrow a helmet from Eric Libutan. The taking was a result of an honest mistake, as Farrales immediately sought to rectify it upon learning he took the wrong helmet. His act did not constitute serious misconduct or willful breach of trust, which are just causes for dismissal. The Court emphasized that in termination cases, the cause must be a serious and grave malfeasance to justify deprivation of livelihood, and all doubts are resolved in favor of labor. The award of attorney’s fees was proper as Farrales was compelled to litigate to secure his rightful claims.