GR L 13778; (April, 1960) (Digest)
G.R. No. L-13778. April 29, 1960.
PHILIPPINE EDUCATION CO., INC., petitioner, vs. UNION OF PHILIPPINE EDUCATION EMPLOYEES (NLU) and THE COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The Philippine Education Company, Inc. (petitioner) appealed from an order of the Court of Industrial Relations (CIR) directing it to reinstate former employee Ernesto Carpio without backpay. Carpio, a union member, participated in a strike on January 16, 1953. After the labor dispute was settled, the CIR ordered the reinstatement of strikers, including Carpio. The company opposed Carpio’s reinstatement because a criminal complaint for theft of company magazines had been filed against him. Carpio was convicted by the Municipal Court of Manila and sentenced to two months and one day of arresto mayor. On appeal, the Court of First Instance acquitted him on the ground of reasonable doubt. The CIR, after reviewing the evidence from the criminal case, agreed with the acquittal and held Carpio entitled to reinstatement, albeit without backpay.
ISSUE
Whether the acquittal of an employee in a criminal case for theft, particularly on the ground of reasonable doubt, entitles the employee to reinstatement by the employer.
RULING
No. The Supreme Court reversed the CIR’s orders. The Court held that an acquittal in a criminal case, especially one based on reasonable doubt, does not bar an employer from refusing reinstatement on the ground of loss of confidence. The evidence required for conviction in a criminal case (proof beyond reasonable doubt) differs from that needed to establish liability in civil or non-criminal matters (preponderance of evidence). Citing National Labor Organization of Employees and Laborers vs. Court of Industrial Relations (95 Phil., 727) and National Labor Union vs. Standard Vacuum Oil Company (73 Phil., 279), the Court emphasized that an employer may dismiss or refuse to reinstate an employee if facts exist that justify loss of confidence, even if the employee is acquitted criminally. The employer-employee relationship, especially where the employee handles merchandise, hinges on trust. The company’s refusal to reinstate Carpio was not due to union affiliation or unfair labor practice but because it had ample reason to distrust him after the theft charge, notwithstanding his acquittal on reasonable doubt. Requiring reinstatement under such circumstances would be unfair to the employer.