G.R. No. 94294 ; March 22, 1991
JOEL MENDOZA, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, SAN MIGUEL CORPORATION, MAGNOLIA DIVISION and CONRAD YUMAN III, respondents.

FACTS

Petitioner Joel Mendoza was a regular salesman for San Miguel Corporation (SMC). On June 2, 1988, he submitted an accident report stating that on May 31, 1988, around 9:30-10:30 PM, the company truck he was driving slipped off the road while he was searching for a missing freezer after making a legitimate collection. However, a police report indicated the accident occurred on June 1, 1988, at 1:00 AM. This discrepancy prompted SMC to conduct a formal investigation on June 16, 1988.
During the investigation, Mendoza admitted he had falsified his initial report. He confessed that after an unsuccessful collection attempt, he and a companion used the company vehicle to watch a PBA game and then proceeded to a drinking session at “Rock Session.” The accident happened as he was driving home afterwards. He pleaded for leniency, acknowledging the gravity of his offense. SMC subsequently terminated him for gross negligence, citing violations including driving under the influence, unauthorized use of a company vehicle, and causing major damage.

ISSUE

Whether the dismissal of petitioner was effected with due process and whether the penalty of dismissal was justified.

RULING

The Supreme Court upheld the dismissal, finding no denial of due process and that the penalty was justified. On due process, the Court ruled that the essence of procedural due process in administrative proceedings is simply an opportunity to be heard. The formal investigation conducted by SMC, where Mendoza was given the chance to explain and where he voluntarily confessed to the true circumstances, satisfied this requirement. The substance of fairness was met, and technical rules of procedure need not be strictly observed.
On the merits of the dismissal, the Court found the penalty of termination to be lawful and proportionate. Mendoza’s actions constituted serious misconduct and gross negligence. He not only drove under the influence and used company property for personal purposes, causing a total wreck, but he also deliberately submitted a false official report to conceal his infractions. Furthermore, the Court noted he was not a first-time offender, having been previously suspended for thirty days in 1986 for failure to remit collections. The totality of his infractions, including dishonesty, amply supported the finding of loss of trust and confidence, justifying dismissal. The NLRC did not commit grave abuse of discretion in reversing the Labor Arbiter’s reinstatement order.