G.R. No. 215047 . November 23, 2016
UNIVERSAL CANNING INC., MS. MA. LOURDES A. LOSARIA, PERSONNEL OFFICER, AND ENGR. ROGELIO A. DESOSA, PLANT MANAGER, PETITIONERS, VS. COURT OF APPEALS AND DANTE SAROSAL, FRANCISCO DUMAGAL, JR., NELSON E. FRANCISCO, ELMER C. SAROMINES AND SAMUEL D. CORONEL, RESPONDENTS.

FACTS

Petitioner Universal Canning Inc. dismissed respondents Dante Sarosal, Francisco Dumagal Jr., Nelson Francisco, Elmer Saromines, and Samuel Coronel, rank-and-file employees, on February 19, 2009. The termination was based on an incident on January 21, 2009, where they were allegedly caught playing cards within company premises during working hours. The company charged them with taking part in an unauthorized game of chance while on duty and for loss of trust and confidence. Respondents admitted playing cards but contended it occurred during their authorized noon break and involved no monetary stakes, thus not constituting gambling.
The Labor Arbiter dismissed the respondents’ complaint for illegal dismissal, finding the dismissal was for just cause and executed with due process. The National Labor Relations Commission (NLRC) affirmed this decision, ruling that playing cards during office hours, regardless of stakes, constituted dishonesty by stealing company time. On certiorari, the Court of Appeals reversed the NLRC, declaring the dismissal illegal. The appellate court held that loss of trust and confidence was inapplicable to rank-and-file employees like the respondents and that the act did not amount to serious misconduct warranting termination.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC and declaring the dismissal of the respondents as illegal.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the NLRC decision which upheld the validity of the dismissal. The Court anchored its ruling on the management prerogative of the employer to regulate all aspects of employment, including discipline and dismissal, provided it is exercised reasonably, in good faith, and without circumventing workers’ rights. The Court deferred to the factual findings of the Labor Arbiter and the NLRC, emphasizing that it is not a trier of facts, especially in labor cases where quasi-judicial bodies’ findings supported by substantial evidence are accorded respect.
The legal logic is that the employer’s company rules, which prohibit gambling or unauthorized games during work hours, were validly enforced. The respondents’ act of playing cards during company time, as found by the labor tribunals, constituted an infraction justifying dismissal under the principle of management prerogative. The Court rejected the appellate court’s narrow view, noting that the infraction was not merely evaluated as “gambling” but as dishonesty and misuse of paid working hours, which is a valid cause for termination under Article 297 (formerly 282) of the Labor Code. The length of service of the respondents was correctly deemed not to mitigate the offense, as loyalty and concern for the company’s interests are expected from all employees.