G.R. No. 75907 March 23, 1992
Family Planning Organization of the Philippines, Inc., petitioner, vs. The National Labor Relations Commission and Homer Agnote, respondents.

FACTS

Petitioner Family Planning Organization of the Philippines, Inc. is a domestic corporation. Private respondent Homer B. Agnote was employed by petitioner, eventually becoming the Section Head of the Program Services Section. On April 5, 1981, Agnote used a company vehicle for personal purposes without authorization. Petitioner issued a memorandum reminding him and two security guards of the proper procedure for releasing vehicles. On April 25, 1981, Agnote reported for work. That evening, the same company vehicle was taken without authorization and met an accident. Agnote and the two security guards were passengers. On June 4, 1981, Agnote received a letter suspending him effective June 5, 1981, and subsequently dismissing him for cause effective July 4, 1981. On June 8, 1981, Agnote filed a complaint for illegal dismissal. On June 11, 1981, petitioner filed a clearance application to terminate Agnote effective July 4, 1981. The Executive Labor Arbiter found petitioner guilty of illegal dismissal, ordering Agnote’s reinstatement with full backwages and other benefits. The National Labor Relations Commission affirmed this decision. Petitioner elevated the case via certiorari.

ISSUE

Whether the National Labor Relations Commission gravely abused its discretion in affirming the Labor Arbiter’s decision that the dismissal of private respondent Homer B. Agnote was illegal.

RULING

The Supreme Court partially granted the petition. It held that the NLRC gravely abused its discretion. The Court found that Agnote’s act of riding the company car, which was taken without authorization, constituted a flagrant violation of an established company rule and amounted to willful disobedience, a just cause for dismissal under Article 283 of the Labor Code. The Court emphasized the employer’s prerogative to prescribe reasonable rules and the employee’s duty to obey them. Furthermore, the Court ruled that petitioner complied with the procedural due process requirement by filing a prior clearance application for termination on June 11, 1981, before the effective date of dismissal on July 4, 1981. Therefore, the dismissal was legal. The complaint for illegal dismissal and illegal suspension was dismissed, and the order for reinstatement with payment of full backwages was set aside. However, the other monetary awards (unpaid per diems, allowances, accrued vacation/service incentive leave, and 13th month pay) totaling P6,549.00 were affirmed, as petitioner failed to contest them.