G.R. No. 217970 , June 17, 2020
Nippon Express Philippines Corporation, Petitioner, vs. Marie Jean Daguiso, Respondent.

FACTS

Petitioner Nippon Express Philippines Corporation (NEPC) hired respondent Marie Jean Daguiso as Corporate Human Resource Specialist in 2005, later promoting her to Corporate Human Resource Supervisor. On June 1, 2012, a conflict arose when Daguiso’s subordinate, Diane Aguirre, sent an email to department heads reassigning attendance monitoring duties without copying Daguiso. Daguiso confronted Aguirre, leading to a shouting match. Daguiso later sent an email to Senior Manager Yolanda De Vera apologizing but questioning the lack of prior information. De Vera, who was out of the office, instructed via her executive assistant to stop the email discussion and focus on work. Daguiso sent a reply email during her breaktime, insisting the matter needed proper action. Upon De Vera’s return later that day, Daguiso was called to a meeting, informed of her termination, and handed a termination letter effective immediately. The letter cited violations of company policy on conduct and discipline, specifically discourtesy, use of coercion/intimidation, and refusal to carry out official instructions, constituting serious misconduct under the Labor Code. Daguiso filed a complaint for illegal dismissal, arguing she was dismissed without just cause and without due process (no written notice to explain or formal hearing). NEPC contended the dismissal was for just cause due to Daguiso’s serious misconduct and willful disobedience, and that due process was satisfied as she was caught in the act and the termination notice sufficed.

ISSUE

Whether respondent Marie Jean Daguiso was illegally dismissed.

RULING

Yes, the Supreme Court ruled that Daguiso was illegally dismissed. The employer failed to prove by substantial evidence that Daguiso’s acts constituted serious misconduct or willful disobedience warranting dismissal. The incident, a heated argument with a subordinate, was an isolated event and not of such grave character as to reflect on her integrity and show her to be unfit for service. Her subsequent email, sent during her breaktime and expressing her view that the matter needed proper action, did not constitute willful disobedience of a lawful order as it was not delivered in a defiant or offensive manner. Furthermore, the dismissal was effected without due process. The employer did not comply with the twin-notice requirement; Daguiso was not given a written notice specifying the grounds for termination and an opportunity to respond, nor a written notice of the decision to dismiss. The termination letter served only as a notice of dismissal, not the required prior notices. Consequently, Daguiso is entitled to reinstatement without loss of seniority rights and to full backwages from the time her compensation was withheld until actual reinstatement. The award of separation pay in lieu of reinstatement by the NLRC was set aside, as reinstatement is the primary relief for an illegally dismissed employee, and the alleged strained relations were not sufficiently proven to make reinstatement inappropriate.