G.R. No. 255864. July 06, 2022
UNIVERSAL ROBINA CORPORATION, PETITIONER, VS. ROBERTO DE GUZMAN MAGLALANG, RESPONDENT.

FACTS

Respondent Roberto Maglalang, a machine operator for petitioner Universal Robina Corporation (URC) since 1997, was found to have a company-owned bottle of ethyl alcohol in his bag during a routine security inspection on March 26, 2015. He panicked and discarded the bottle, which was recovered by the guard. URC charged him with qualified theft, placed him under preventive suspension, and issued a Notice to Explain. Maglalang admitted taking the bottle but denied intent to steal, claiming he forgot to return it after using it to clean his motorcycle. After an administrative hearing, URC terminated him for serious misconduct and willful breach of trust. A criminal case was filed but later dismissed following a compromise agreement where URC withdrew the complaint and both parties waived claims against each other. Maglalang subsequently filed an illegal dismissal case.
The Labor Arbiter and the National Labor Relations Commission upheld the dismissal, finding Maglalang guilty of serious misconduct. The Court of Appeals reversed, ruling the dismissal illegal. It held that the act constituted only simple misconduct, not serious misconduct, as the item, valued at ₱60.00, was immediately recovered, and Maglalang did not occupy a position of trust. The CA awarded backwages and separation pay. URC elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in ruling that Roberto Maglalang was illegally dismissed.

RULING

The Supreme Court denied URC’s petition and affirmed, with modification, the CA’s finding of illegal dismissal. The Court held that for misconduct to be a valid ground for dismissal under Article 297 of the Labor Code, it must be serious—characterized by willfulness, wrongful intent, and a transgression of established rules. The misconduct must also be connected to the employee’s work. The Court found Maglalang’s act, while dishonest, did not rise to the level of serious misconduct warranting termination. The alcohol was of minimal value (₱60.00), was recovered immediately, and was taken for personal use, not for gain. His long, unblemished 18-year service further mitigated the offense’s gravity. The Court also ruled he was not a confidential employee, so loss of trust was inapplicable.
However, the Court modified the CA award. It deleted the grant of backwages because Maglalang was not entirely innocent; his act constituted simple misconduct justifying suspension. The compromise agreement’s waiver was also deemed not to bar the illegal dismissal claim, as it pertained only to the criminal case. Consequently, the Court upheld the award of separation pay in lieu of reinstatement due to strained relations, remanding the case to the Labor Arbiter for its computation from his hiring in 1997 until his illegal dismissal. Attorney’s fees were also deleted.