G.R. No. L-15826. January 23, 1961.
ORMOC SUGAR CO., INC. and RODOLFO M. REVILLA, petitioners, vs. OSCO WORKERS FRATERNITY LABOR UNION (OWFLU), BENITO PORCADILLA and THE HONORABLE JOSE S. BAUTISTA, AMENIO I. MARTINEZ, BALTAZAR M. VILLANUEVA and EMILIANO C. TABIGNE, as Judges of the COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The respondent OSCO Workers Fraternity Labor Union (OWFLU) filed a complaint for unfair labor practice against Ormoc Sugar Company, Inc. and its resident manager, Rodolfo M. Revilla, before the Court of Industrial Relations (CIR). The union alleged interference with union activities and the dismissal without just cause of union officers, including Benito Porcadilla. The company countered that the dismissals, including that of Porcadilla, were for valid causes, specifically sleeping during working hours. After a hearing, the CIR found the company guilty of unfair labor practices. While it upheld the dismissal of two other employees, it ruled that Porcadilla’s dismissal lacked just cause and ordered his reinstatement with backwages. The company’s motion for reconsideration was denied by the CIR en banc, prompting this petition for certiorari.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion in finding no just cause for the dismissal of Benito Porcadilla and ordering his reinstatement.

RULING

Yes. The Supreme Court set aside the CIR’s order for reinstatement, declaring Porcadilla’s dismissal valid. While the factual findings of the CIR are generally conclusive, they must be supported by substantial evidence. In this case, the CIR erred in disregarding the substantial evidence presented by the company. The petitioners presented the testimonies of resident manager Revilla, two security guards, and three co-workers, all of whom consistently testified that Porcadilla was caught sleeping during his shift on two occasions—April 22, 1957, for which he was fined and warned, and again on May 17, 1957, which led to his dismissal. In contrast, Porcadilla merely offered a self-serving denial. The Court found the testimonies of the five disinterested co-workers credible, as they had no apparent motive to testify falsely. Porcadilla’s own testimony, wherein he admitted that Revilla had someone wake him up during the second incident but he did not protest that he was not asleep, undermined his denial. Sleeping during working hours constitutes a serious dereliction of duty and a valid cause for dismissal. The existence of this just cause negates any claim that the dismissal was due to union activity, an element of unfair labor practice. Therefore, the CIR’s finding was not supported by substantial evidence.