GR 223485; (December, 2019) (Digest)
G.R. No. 223485 , December 04, 2019
DEL MONTE FRESH PRODUCE (PHIL.), INC., PETITIONER, VS. REYNALDO P. BETONIO, RESPONDENT.
FACTS
Petitioner Del Monte Fresh Produce (PHIL.), Inc. (DMFPPI) employed respondent Reynaldo P. Betonio as Manager for Port Operations on September 1, 2008, promoting him to Senior Manager on April 1, 2009. Beginning April 2010, DMFPPI’s Human Resource Department received reports and complaints from various managers, directors, and clients regarding Betonio’s inefficiencies in port operations. On June 21, 2010, DMFPPI issued a Show Cause Memo charging Betonio with gross and habitual neglect of duties and breach of trust and confidence, detailing 12 specific infractions. Betonio submitted a written explanation and attended an administrative hearing on July 1, 2010. The Administrative Committee, while finding Betonio inefficient, recommended dismissal of the charges. However, DMFPPI’s top management issued a Notice of Disciplinary Action on July 21, 2010, terminating Betonio’s employment. Betonio filed a complaint for illegal dismissal. The Labor Arbiter ruled in favor of Betonio, ordering reinstatement and payment of backwages. The National Labor Relations Commission (NLRC) initially reversed the Labor Arbiter, dismissing the complaint, but upon Betonio’s motion for reconsideration, reinstated the Labor Arbiter’s decision. DMFPPI filed a Petition for Certiorari with the Court of Appeals, which affirmed the NLRC’s reinstatement of the Labor Arbiter’s ruling, finding the dismissal illegal. DMFPPI appealed to the Supreme Court.
ISSUE
1. Whether Betonio was legally dismissed on the ground of loss of trust and confidence.
2. Whether his dismissal was made with due process of law.
RULING
1. Yes, Betonio was legally dismissed on the ground of loss of trust and confidence. The Supreme Court held that as a Senior Manager, Betonio was a fiduciary employee occupying a position of trust and confidence. His repeated inefficiencies and failure to properly manage port operations, as substantiated by affidavits, emails, reports, and complaints from employees and clients, constituted a breach of the trust reposed in him. The Court found that Betonio’s lapses were not mere ordinary neglect but were willful and recurrent, adversely affecting the company’s operations. The NLRC’s initial Decision, which found the dismissal valid based on loss of trust and confidence, was reinstated.
2. No, the dismissal was not made with due process of law. The Court found that DMFPPI failed to comply with procedural due process. The Notice of Disciplinary Action (termination letter) was issued on July 21, 2010, but the Show Cause Memo was dated June 21, 2010, and the hearing was held on July 1, 2010. The Court noted that the administrative process appeared to be an “empty ceremony” as the decision to dismiss seemed to have been made prior to the completion of the investigation, evidenced by the HR Manager’s earlier suggestion for Betonio to resign voluntarily to avoid an investigation. Consequently, while the dismissal was for a valid cause, the procedural defect warranted the award of nominal damages.
DISPOSITIVE PORTION:
The Supreme Court GRANTED the petition. The Decision and Resolution of the Court of Appeals were REVERSED and SET ASIDE. The NLRC Decision dated December 29, 2011, which dismissed Betonio’s complaint for illegal dismissal, was REINSTATED. However, for noncompliance with procedural due process, DMFPPI was ORDERED to pay Betonio nominal damages in the amount of P30,000.00.