G.R. No. 90030 June 25, 1990
MANILA ELECTRIC COMPANY, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and JIMMY MEGINO, respondents.

FACTS

Jimmy Megino was employed as a teller by Manila Electric Company (MERALCO) at its San Pedro Branch. His duties included collecting bill payments and remitting them daily. In December 1985, he was preventively suspended pending an administrative investigation for unremitted collections totaling P1,864.89 and delayed remittances amounting to P3,763.51. During the investigation, Megino admitted collecting the sums but blamed a former co-worker, Myle Calayag, for the anomalies. MERALCO found him guilty of misappropriating company funds, a violation of its Code of Employee Discipline warranting dismissal, and terminated his employment on February 12, 1986.
Subsequently, in April 1986, Myle Calayag executed a sworn statement admitting he caused the shortages by swapping collection stubs. However, a final audit report by MERALCO later revealed that Megino had misappropriated a total of P63,967.15 over the years. Megino filed a complaint for illegal dismissal. The Labor Arbiter dismissed his complaint, finding the dismissal valid due to loss of trust and confidence. On appeal, the NLRC reversed the Arbiter, ruling the dismissal illegal for lack of factual and legal basis, and ordered Megino’s reinstatement with full backwages.

ISSUE

Whether the NLRC committed grave abuse of discretion in ruling that Jimmy Megino was illegally dismissed.

RULING

Yes, the NLRC committed grave abuse of discretion. The Supreme Court reinstated the Labor Arbiter’s decision, upholding Megino’s dismissal for just cause. The legal logic centers on loss of trust and confidence as a valid ground for termination under Article 282 of the Labor Code. The Court clarified that proof beyond reasonable doubt is not required; it is sufficient that the employer has reasonable grounds to believe the employee committed acts rendering him unworthy of the trust demanded by his position. Megino, as a teller handling company funds, held a position of utmost confidence. His admitted failure to remit collections, coupled with the subsequent audit finding of a substantial misappropriation over time, provided MERALCO with more than ample basis to lose trust in him. The later admission by Calayag did not absolve Megino, as the employer’s reasonable belief at the time of dismissal, supported by investigation, was legally sufficient. The right to security of tenure is not absolute and yields when, as here, an employee commits dishonesty prejudicial to the employer’s interests. Therefore, his dismissal was justified.