G.R. No. 71499 July 19, 1989
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION & JAIME L. ALEJANDRINO, respondents.

FACTS

The petitioner, Philippine Long Distance Telephone Company (PLDT), dismissed its employee, Jaime Alejandrino, a telephone installer, after he was apprehended by Quezon City policemen in the act of siphoning gasoline from a PLDT service vehicle. During police investigation, Alejandrino admitted to the theft. A criminal charge for qualified theft was subsequently filed. Upon being notified by PLDT to explain in writing why he should not be dismissed for theft, Alejandrino submitted a written explanation denying the act, claiming he was framed, and concluding he was ready to be heard in a formal inquiry if certain matters needed clarification.
PLDT dismissed Alejandrino on April 14, 1983, based on his sworn admission to the police, the affidavits of the arresting officers, and the fiscal’s disposition report. Alejandrino filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, finding just cause for dismissal. However, the National Labor Relations Commission (NLRC) reversed this decision on appeal, ordering Alejandrino’s reinstatement without backwages on the sole ground that he was dismissed without due process, specifically, without a proper hearing.

ISSUE

Whether or not the NLRC committed grave abuse of discretion in ruling that Alejandrino was dismissed without due process.

RULING

Yes, the Supreme Court granted PLDT’s petition, finding that the NLRC gravely abused its discretion. The Court held that the constitutional requirement of due process in administrative proceedings does not always necessitate a trial-type hearing. The essence of due process is simply an opportunity to be heard or to explain one’s side.
This requirement was satisfied when PLDT notified Alejandrino of the charge against him and he was given the opportunity to defend himself, which he availed of by submitting a detailed written explanation to his manager. The Court emphasized that Alejandrino did not positively demand a formal hearing; he merely expressed conditional readiness for one if clarifications were needed. PLDT cannot be faulted for not conducting a formal inquiry when it found the evidence in its possession—the police affidavits and Alejandrino’s own prior admission—to be already clear and sufficient.
The Court upheld the Labor Arbiter’s factual findings, which gave credence to the policemen’s candid testimonies and the presumption of regularity in their duties. It noted that Alejandrino’s handwritten addition to his police statement, claiming he was merely recovering a personal cash advance for gasoline, was illogical and did not exonerate him. Acts of dishonesty involving company property constitute serious misconduct and a valid ground for dismissal. Therefore, the NLRC decision was set aside and the Labor Arbiter’s decision dismissing the complaint was reinstated.