G.R. No. 228765 . March 20, 2019.
MINDA TOPINIO CADAVAS, PETITIONER, vs. COURT OF APPEALS, CAGAYAN DE ORO CITY, TWENTY-THIRD DIVISION, AND DAVAO DOCTORS HOSPITAL AND/OR RAYMUNDO DEL VAL, PRESIDENT, RESPONDENTS.

FACTS

Petitioner Minda Cadavas was a Nurse Supervisor at Davao Doctors Hospital (DDH). In February 2012, her aunt was confined at DDH. To reduce her aunt’s hospital expenses, Cadavas, with the assistance of subordinate staff, obtained medical supplies and medicines from the hospital’s Emergency Department and Operating Room Central Supply Service. These items, valued at approximately P6,000, were used for her aunt’s procedures but were not recorded or charged to the patient’s bill, based on Cadavas’s arrangement to replace them later with items purchased outside the hospital, which she subsequently did.
DDH issued a notice to explain, and after an administrative hearing where Cadavas admitted the acts and her awareness of the policy against such practices, she was terminated for dishonesty and loss of trust and confidence. Cadavas filed a complaint for illegal dismissal, arguing the penalty was too harsh for a first offense in 23 years of service and that she was denied due process by not having counsel during the hearing. The Labor Arbiter ruled in her favor, but the NLRC reversed, finding the dismissal valid. The Court of Appeals affirmed the NLRC.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in affirming the NLRC’s ruling that petitioner was validly dismissed for just cause.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic centered on the validity of dismissal based on loss of trust and confidence under Article 282 of the Labor Code. For loss of trust to be a valid cause, the breach must be willful, founded on clearly established facts, and the employee must hold a position of trust. As a Nurse Supervisor, Cadavas occupied such a fiduciary position. Her admission that she deliberately circumvented hospital policy by having supplies withdrawn without proper charging, influencing subordinates to comply, constituted a willful act of dishonesty that eroded the trust inherent in her supervisory role.
The Court rejected the argument that dismissal was too harsh, emphasizing that the act was not a mere error in judgment but a deliberate violation justifying severance of the employment relationship. The presence of just cause rendered the issue of due process moot, as any procedural defect did not negate the substantive validity of the dismissal. The employer’s loss of confidence, given the breach of honesty directly related to her duties, was reasonable and justified termination. Consequently, she was not entitled to separation pay.