GR 90173; (February, 1991) (Digest)
G.R. No. 90173; February 27, 1991
MANGGAGAWA NG KOMUNIKASYON SA PILIPINAS AND BARTOLOME O. ANDRADA, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION AND PHILIPPINE LONG DISTANCE TELEPHONE COMPANY (PLDT), respondents.
FACTS
Deo Motus applied for a telephone connection, changing his address multiple times upon alleged advice of PLDT employee Bartolome Andrada. When installation repeatedly failed at his desired location, Motus’s mother, Florentina, lodged a complaint with PLDT, accusing Andrada of demanding and receiving P1,500 to facilitate the installation. PLDT conducted an investigation, during which Andrada initially invoked his right against self-incrimination but later participated in a formal hearing. He was subsequently found guilty of serious misconduct and dismissed. Andrada and his union filed an illegal dismissal case. The Labor Arbiter ruled in Andrada’s favor, ordering reinstatement and backwages, but the NLRC reversed this decision on appeal.
ISSUE
Whether the NLRC committed grave abuse of discretion in upholding Andrada’s dismissal based on the evidence presented by PLDT.
RULING
The Supreme Court granted the petition, annulling the NLRC decision and reinstating the Labor Arbiter’s ruling. The Court held that PLDT failed to discharge its burden of proving by substantial evidence that Andrada committed serious misconduct warranting dismissal. The employer bears this burden in termination cases due to the constitutional protection of security of tenure. The evidence consisted of conflicting sworn statements: Florentina Motus’s accusation against Andrada’s denial, supported by the sworn statements of two witnesses, Venancia Pulido and Socorro Lao, who were neighbors and friends of the complainant yet refuted her allegations. The Court found these corroborating witness statements credible, tilting the scales in Andrada’s favor. It further noted the inherent improbability that Andrada would risk his stable employment for a minimal sum. The NLRC’s disregard for this exculpatory evidence constituted grave abuse of discretion. The Court emphasized the necessity of extreme caution in terminating employment, as a worker’s job is a vital lifeline.