GR 75662; (September, 1989) (Digest)
G.R. No. 75662 September 15, 1989
MERCURY DRUG CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, NLRC SHERIFF and CESAR E. LADISLA, respondents.
FACTS
Private respondent Cesar E. Ladisla was employed as a Stock Analyst at Mercury Drug Corporation’s Claro M. Recto Branch. On August 15, 1977, he was apprehended by company representatives while pilfering three bottles of Persantin and one bottle of Valoron, with a total value of P272.00. Ladisla admitted his guilt in a handwritten statement and verbally confirmed it at the police station, as documented in a signed Booking Sheet and Arrest Report. Consequently, on August 19, 1977, Mercury Drug placed him on preventive suspension and filed an application with the Department of Labor for clearance to terminate his employment on grounds of dishonesty and breach of trust. Ladisla opposed the application, alleging the charges were a frame-up by his superiors and that he was not given an opportunity to explain his side.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in ordering the reinstatement of Cesar E. Ladisla despite his conviction for theft related to the act constituting the ground for his dismissal.
RULING
The Supreme Court reversed the NLRC resolution and reinstated the Labor Arbiter’s decision validating Ladisla’s dismissal. The Court held that the NLRC committed grave abuse of discretion in disregarding the material significance of Ladisla’s criminal conviction. Prior to the NLRC’s decision, the Regional Trial Court had already found Ladisla guilty of simple theft for the same pilferage incident. This criminal conviction, which attained finality after Ladisla availed of probation and did not appeal, constituted proof beyond reasonable doubt of the act that formed the basis for loss of trust and confidence.
The legal logic is clear: an employer has the right to dismiss an employee for fraud or willful breach of trust under Article 282(c) of the Labor Code. Loss of confidence is a valid ground when the employer has ample reason to mistrust the employee. Here, the final conviction for theft fortified the employer’s loss of trust. The Court emphasized that the law authorizes neither oppression of labor nor self-destruction of the employer. While the Constitution mandates protection for labor, justice must be dispensed based on established facts and applicable law. Management’s right to dismiss employees for acts inimical to its interest, such as dishonesty, is essential for its self-protection. The preventive suspension was justified, and Ladisla was afforded due process through investigations at the police precinct and the labor arbitration proceedings.