GR 214301; (June, 2017) (Digest)
G.R. No. 214301, June 1, 2017
RAMON MANUEL T. JAVINES, Petitioner, vs. XLIBRIS a.k.a. AUTHOR SOLUTIONS, INC., JOSEPH STEINBACH, and STELLA MARS OUANO, Respondents.
FACTS
Petitioner Ramon Manuel T. Javines was hired as Operations Manager by respondent Xlibris on September 1, 2011. On July 27, 2012, approximately ten months later, his employment was terminated for allegedly falsifying three meal receipts submitted for reimbursement. The tampering, which significantly inflated the amounts, was discovered by the finance department. Xlibris issued a Notice to Explain, conducted an administrative hearing on July 13, 2012, and subsequently sent notices to the supervisors under Javines, who all denied involvement.
Javines filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, finding the dismissal was for just cause and with due process. On appeal, the National Labor Relations Commission (NLRC) modified the decision, holding that while the dismissal was for just cause (dishonesty), procedural due process was not fully observed because Javines was not given an opportunity to confront the supervisors’ written denials after the initial hearing before his termination. The NLRC awarded Javines PhP 10,000 in nominal damages.
ISSUE
Whether the Court of Appeals erred in affirming the NLRC’s finding that Javines was dismissed for just cause.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal logic rests on the finality of the NLRC’s factual finding on just cause and the limited scope of a Rule 45 review. The Labor Arbiter and the NLRC unanimously found that Javines was dismissed for the just cause of dishonesty under Article 297 of the Labor Code. Javines failed to file a motion for reconsideration of the NLRC decision or to timely challenge this specific finding before the Court of Appeals via a petition for certiorari. Consequently, the NLRC’s finding on the existence of a just cause for dismissal attained finality and was beyond the appellate court’s power of review.
The petition before the Supreme Court, being a review under Rule 45 of the Rules of Court, is limited to questions of law. The Court emphasized that it is not a trier of facts and generally defers to the factual findings of quasi-judicial agencies like the NLRC, especially when affirmed by the Court of Appeals. Javines’ attempt to re-litigate the sufficiency of evidence for his dismissal constitutes a question of fact, which is not permissible in a Rule 45 petition. Having found no compelling reason to deviate from these settled doctrines, the Supreme Court upheld the CA’s ruling, including the reduction of nominal damages to PhP 1,000 for the procedural lapse.