G.R. No. 217896 , June 26, 2019
The Heritage Hotel, Manila, Petitioner vs. Lilian Sio, Respondent

FACTS

Petitioner The Heritage Hotel Manila employed respondent Lilian Sio as a Service Agent. Two incidents led to her suspension. First, on April 29, 2011, a VIP guest, Erlinda Tiozon, complained about Sio’s discourteous and sarcastic behavior when processing a food order using a Player Tracking System. After investigation, Heritage found Sio guilty of major offenses under its Code of Conduct and imposed a one-week suspension, which she served. Second, on September 21, 2011, another guest, Mussa Mendoza, complained that Sio made an arrogant remark, stating, “Ikaw na magexplain sa kanya at baka maghanap pa siya,” after a canceled order. Heritage again found Sio guilty of discourtesy and conduct inimical to the hotel’s interest, imposing a two-week suspension with a warning.
Sio filed a complaint for illegal suspension and unfair labor practice. The Labor Arbiter dismissed her complaint, upholding the suspensions as a valid exercise of management prerogative. The NLRC affirmed this decision. However, the Court of Appeals reversed, finding the suspensions illegal. It held that the first suspension was based on a complaint from a co-employee (Bumatay), not the guest herself, and that the second incident involved a remark not directed at the complaining guest, thus lacking substantial evidence of guilt.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC and declaring Sio’s suspensions illegal.

RULING

Yes, the Supreme Court reversed the CA and reinstated the NLRC decision. The legal logic is anchored on the principle that factual findings of quasi-judicial agencies like the NLRC, when supported by substantial evidence, are accorded respect and finality. The Court found that the CA improperly re-evaluated the evidence and substituted its own judgment. Substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, existed for both suspensions.
For the first incident, Sio’s guilt was established not merely by her co-employee’s report but by her own conduct during the administrative hearing where she apologized and signed the minutes, effectively admitting the charges. For the second incident, the remark, though directed at the guest’s companion, was uttered within the guest’s hearing, causing offense and embarrassment, which constitutes discourtesy affecting the hotel’s service reputation. The employer’s Code of Conduct reasonably classified such acts as major offenses. Heritage complied with procedural due process by issuing memoranda, conducting hearings, and allowing Sio to explain. Therefore, the suspensions were a legitimate exercise of management prerogative to discipline employees for behavior prejudicial to company interests. The NLRC’s finding of valid suspension was supported by substantial evidence.