GR 87974; (July, 1990) (Digest)
G.R. No. 87974 July 2, 1990
BRISTOL LABORATORIES EMPLOYEES’ ASSOCIATION-DFA and RICO G. GATA, petitioners, vs. THE NATIONAL LABOR RELATIONS COMMISSION, BRISTOL LABORATORIES (PHILS.), INC., F.A. MARIAZETA, J.F. FUENTES, JR., CARLITO S. VILLANUEVA, respondents.
FACTS
Petitioner Rico G. Gata was a Territory Manager for Bristol Laboratories. In March 1987, the company charged him with unauthorized stock withdrawals from two customer accounts, issuing personal checks that subsequently bounced. After being directed to explain and undergoing a formal investigation where he was confronted with documentary evidence, Gata was dismissed for serious misconduct and willful breach of trust. Gata filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint for lack of merit, finding the dismissal was for just cause and with due process, but anomalously awarded Gata separation pay. Both parties appealed to the NLRC. The NLRC, considering additional documentary evidence submitted by the company on appeal, issued a resolution vacating the Labor Arbiter’s decision and remanding the case for further reception of evidence. Petitioners assailed this resolution via certiorari.
ISSUE
Whether the NLRC committed grave abuse of discretion in remanding the case to the Labor Arbiter for further proceedings instead of resolving the appeal on its merits.
RULING
The Supreme Court granted the petition, finding no grave abuse in the NLRC’s consideration of additional evidence but grave error in its order of remand. The Court held that procedural technicalities are not strictly applied in labor proceedings, and the NLRC may consider evidence submitted on appeal to ascertain facts speedily, as sanctioned by Article 221 of the Labor Code. However, the NLRC should have resolved the case on the merits. The Labor Arbiter’s factual findings, supported by substantial evidence, were binding. These findings established that Gata, a managerial employee holding a position of trust, committed unauthorized acts in violation of company policy, constituting a willful breach of confidence that justified his dismissal after being afforded due process. The award of separation pay by the Labor Arbiter was erroneous, as an employee dismissed for cause is not entitled to it. However, since the company did not appeal that portion of the decision, it was not entitled to affirmative relief. The Court set aside the NLRC’s resolution and reinstated the Labor Arbiter’s decision dismissing the complaint for illegal dismissal.