G.R. No. 212054 . March 11, 2015.
ST. LUKE’S MEDICAL CENTER, INC., Petitioner, vs. MARIA THERESA V. SANCHEZ, Respondent.

FACTS

Respondent Maria Theresa V. Sanchez was hired by petitioner St. Luke’s Medical Center, Inc. (SLMC) as a Staff Nurse on June 29, 2009, and assigned to the Pediatric Unit. On May 29, 2011, at the end of her shift, she was subjected to a standard inspection at the SLMC exit. Security Guard Jaime Manzanade found a pouch in her bag containing various medical items (syringes, micropore, cotton balls, neoflon, venofix, gloves). Sanchez asked to return the pouch to the treatment room but was instead brought to the In-House Security Department (IHSD). She was directed to write an Incident Report and also submitted an undated handwritten letter of apology, admitting she brought things from SLMC and that she had been collecting items one by one when she forgot to return them, keeping them for use when stocks were depleted. In a subsequent Incident Report Addendum dated May 31, 2011, she explained the items were excess stocks from discharged patients’ drawers, a practice among staff, and she kept them in a pouch in the treatment room for immediate procedures; she accidentally placed the pouch in her bag when retrieving other items and forgot about it. After investigation and a case conference, SLMC terminated Sanchez on July 6, 2011, for violating Section 1, Rule 1 of the SLMC Code of Discipline (Acts of Dishonesty, i.e., Robbery, Theft, Pilferage). Sanchez filed a complaint for illegal dismissal. The Labor Arbiter ruled the dismissal valid, finding she intentionally took property for personal benefit. The NLRC reversed, declaring the dismissal illegal, noting “hoarding” was a tolerated practice, she lacked ill-will, and dismissal was too harsh a penalty. The CA affirmed the NLRC, ruling the offense was not serious misconduct, no economic damage to SLMC, the practice was tolerated, her demeanor showed lack of intent, and dismissal was disproportionate.

ISSUE

Whether or not Sanchez was illegally dismissed by SLMC.

RULING

The Supreme Court ruled that Sanchez was NOT illegally dismissed; her termination was for a just cause. The Court found that Sanchez committed an act of dishonesty amounting to serious misconduct. Her handwritten letter constituted a clear admission of intentionally taking hospital items over time. The fact that the items were paid for by patients did not negate the dishonesty, as SLMC’s Code of Discipline prohibits such acts against the hospital, its doctors, employees, or customers. The tolerated practice of “hoarding” did not legalize the act, and management had the prerogative to penalize violations of company policy. Her attempt to bring the items outside the premises, despite knowing the inspection procedure, indicated intent. The penalty of dismissal was commensurate, as acts of dishonesty, especially by medical personnel in a hospital setting, justify termination to protect the employer’s integrity. The Court reversed the CA and NLRC decisions and reinstated the Labor Arbiter’s ruling validating the dismissal.