GR 232194; (June, 2019) (Digest)
G.R. No. 232194, June 19, 2019
ALVIN M. DE LEON, Petitioner, vs. PHILIPPINE TRANSMARINE CARRIERS, INC. AND ANNA MARIA MORALEDA, Respondents.
FACTS
Petitioner Alvin M. de Leon was a long-time employee of respondent Philippine Transmarine Carriers, Inc. (PTC), a manning agency, receiving numerous performance awards. PTC had a strict Code of Discipline prohibiting employees from accepting gifts from crew members. In 2010, de Leon was verbally reprimanded for a related incident. The Code was revised in 2012, explicitly stating that accepting any gift from a crew member, ex-crew member, or their representative was a dismissible offense on the first instance.
On October 9, 2013, de Leon was captured on CCTV accepting a bag containing two bottles of whiskey from a crew member, Fred Rikko B. Adefuin. The gift was purportedly from Mustafa Acar, a friend and former co-worker of de Leon from a prior vessel. In his defense, de Leon admitted he instructed Adefuin to give the gift to a co-employee in a different area of the office to avoid being seen on camera, claiming the gift was a personal token from a friend, not a crew member seeking a favor. PTC conducted an investigation and subsequently terminated de Leon’s employment for violating the company rule.
ISSUE
Whether the dismissal of de Leon from employment was legal.
RULING
Yes, the dismissal was legal. The Supreme Court affirmed the rulings of the Court of Appeals and the National Labor Relations Commission. The core issue was the validity of the company rule and its proper application. The Court held that management has the prerogative to prescribe reasonable rules for the conduct of its business. PTC’s rule prohibiting the acceptance of gifts from crew members is reasonable, aimed at preventing corruption, favoritism, and ensuring impartiality in the crewing process, which is a legitimate business interest.
The Court found that de Leon willfully violated this known rule. His own admission that he directed the gift to be transferred to avoid the CCTV camera demonstrates consciousness of guilt and a deliberate attempt to circumvent the policy. The fact that the gift-giver, Acar, was a former co-worker does not absolve him. The rule explicitly covers gifts from “ex-crew members,” and the item was physically delivered by an active crew member (Adefuin), bringing the act squarely within the prohibition’s scope. His act constituted willful disobedience of a lawful company rule, which is a just cause for dismissal under Article 297 of the Labor Code. The dismissal was therefore upheld as a valid exercise of management prerogative.