G.R. No. L-57642 March 16, 1989
Baliwag Transit, Inc., petitioner, vs. Hon. Blas F. Ople, Minister of Labor and Employment, and Romeo Hughes, respondents.

FACTS

Petitioner Baliwag Transit, Inc. employed private respondent Romeo Hughes as a bus driver in 1966. On August 10, 1974, Hughes was driving a company bus when it was stalled at a railroad crossing in Calumpit, Bulacan, due to traffic ahead. While stalled, the bus was struck from behind by a Philippine National Railways train, resulting in numerous fatalities, injuries, and extensive damage. Hughes was prosecuted for multiple homicide and serious physical injuries, but the case was provisionally dismissed in 1980. In a separate civil case for damages filed by Baliwag Transit against the PNR, the trial court absolved Hughes of any contributory negligence. After this absolution and the renewal of his driver’s license, Hughes repeatedly sought reinstatement. The company advised him to wait for the criminal case’s termination and later, in May 1980, formally refused reinstatement, claiming loss of confidence and that his license had been revoked. Hughes then filed a complaint for illegal dismissal in July 1980.

ISSUE

Whether or not Romeo Hughes was illegally dismissed by Baliwag Transit, Inc.

RULING

Yes, the dismissal was illegal. The Supreme Court affirmed the order of the Minister of Labor for reinstatement, modifying the back wages to three years. The petitioner’s grounds for dismissal were untenable. First, the charge of abandonment failed, as the record showed Hughes actively sought reinstatement and served as the company’s witness in its civil case against the PNR, negating any intention to abandon his work. Second, the defense of prescription was rejected; the cause of action accrued from the final denial of reinstatement on May 10, 1980, and the complaint filed in July 1980 was timely. Third, the claim of loss of confidence was baseless. Loss of confidence must be founded on willful breach of trust or actual wrongdoing. The trial court’s finding in the civil case explicitly absolved Hughes of contributory negligence, noting the accident occurred due to circumstances beyond his control as his vehicle was trapped. Given his unblemished record prior to this isolated incident, which was adjudged not his fault, the employer’s loss of confidence was unfounded and constituted a dismissal without just cause. The Court emphasized that security of tenure, a constitutional guarantee, protects workers from arbitrary dismissal, and Hughes was entitled to its protection.