G.R. No. 223582 & 223788, August 07, 2024
RICARDO D. ANGELES, PETITIONER, VS. ST. CATHERINE REALTY CORPORATION, ERWIN S. DIZON, CELESTINO S. DIZON, AND MARIO B. MALLARI, RESPONDENTS. [G.R. No. 223788] ST. CATHERINE REALTY CORPORATION, ERWIN S. DIZON, CELESTINO S. DIZON, AND MARIO MALLARI, PETITIONERS, VS. RICARDO D. ANGELES AND FRANCISCO PACHECO, JR., RESPONDENTS.

FACTS

St. Catherine Realty Corporation (St. Catherine) is engaged in subdivision development. Ricardo D. Angeles was employed from March 2001 to June 1, 2010, working as a driver, marketing staff, and later as surveyor/purchaser. Francisco Pacheco, Jr. was employed from August 2006 to June 1, 2010 as a landscaper. In March 2010, they were instructed to canvass prices for ornamental plants. St. Catherine alleged that Angeles and Pacheco misrepresented the prices from Danbel’s Garden. Based on their canvass, St. Catherine directed the purchase of the plants on March 24, 2010, evidenced by Sales Invoice No. 1134. Later, an on-site inspection revealed the plants had withered and were in excessive quantities. On May 13, 2010, another St. Catherine employee purchased the same items from Danbel’s Garden, evidenced by Sales Invoice No. 1161, which showed significantly lower unit prices. Due to the price disparity, St. Catherine terminated Angeles and Pacheco on June 1, 2010, for “willful breach of the trust reposed” in them. Angeles and Pacheco filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint. The National Labor Relations Commission (NLRC) reversed the LA, finding both employees illegally dismissed, holding that St. Catherine failed to prove the employees occupied positions of trust and failed to refute the garden owner’s explanation that the first plants were bigger and in-demand. The Court of Appeals partially granted St. Catherine’s petition, finding Pacheco was illegally dismissed as he did not hold a position of trust, but Angeles was not illegally dismissed as he occupied a position of trust and confidence as a surveyor/purchaser, and the price discrepancy warranted his termination.

ISSUE

Whether the Court of Appeals erred in ruling that Ricardo D. Angeles was validly dismissed on the ground of loss of trust and confidence.

RULING

The Supreme Court granted Angeles’s petition and denied the petition of St. Catherine et al. The Court held that for dismissal on the ground of loss of trust and confidence to be valid, the employee must be shown to occupy a position of trust and confidence, and there must be substantial evidence of an act justifying the loss of trust. The Court found that St. Catherine failed to prove by substantial evidence that Angeles occupied such a position. His duties as a surveyor/purchaser, which included canvassing prices and purchasing materials, were merely ministerial and did not involve the exercise of discretion and independent judgment characteristic of a managerial employee or the custody and care of company assets indicative of a fiduciary rank-and-file employee. Furthermore, the alleged fraud was not substantiated. The price discrepancy between the two invoices was sufficiently explained by the garden owner’s affidavit stating the first batch of plants were bigger, in-demand, and limited in stock. Fraud is never presumed and must be proved by clear and convincing evidence, which St. Catherine failed to do. Therefore, Angeles’s dismissal was illegal. The Court affirmed the CA’s ruling regarding Pacheco’s illegal dismissal. St. Catherine was ordered to pay Angeles and Pacheco full backwages, separation pay in lieu of reinstatement, and attorney’s fees.