GR L 19892; (September, 1967) (Digest)
G.R. No. L-19892; September 25, 1967
GERONIMO GATMAITAN, plaintiff-appellant, vs. MANILA RAILROAD COMPANY, ET AL., defendants-appellees.
FACTS
Geronimo Gatmaitan was employed as Cashier and Assistant Treasurer of the Manila Railroad Company. On December 11, 1952, he was suspended following the discovery of the encashment of forged treasury warrants exceeding P400,000. On June 30, 1953, he was reinstated to work as an Administrative Assistant pursuant to a Board resolution. He was suspended again on January 27, 1954, after criminal cases for estafa through falsification of public documents were filed against him. During this suspension, his original position was abolished. The Company’s Board created a committee to investigate the matter. Gatmaitan, assisted by counsel, appeared before the committee and submitted a memorandum. The committee found him guilty of misconduct, and the Board, through Resolution No. 814 dated December 16, 1955, decreed his dismissal, with notice given on December 24, 1955. On September 30, 1957, Gatmaitan was acquitted in the criminal cases on the ground that his guilt was not proven beyond reasonable doubt. The Company refused to reinstate him or pay back wages. Gatmaitan filed the present action on August 5, 1958.
ISSUE
Whether the investigations conducted by the Company satisfied the requirements of due process in administrative proceedings, thereby making Gatmaitan’s dismissal valid.
RULING
Yes. The Supreme Court affirmed the lower court’s judgment dismissing the complaint. The Court held that Gatmaitan was given full opportunity to be heard and defend himself during the company investigation, as he appeared before the committee with counsel and submitted a memorandum. His subsequent acquittal in the criminal cases, based merely on reasonable doubt, did not invalidate his dismissal. Conviction in a criminal case is not indispensable to warrant dismissal by an employer; it is sufficient that the employer has proof of the employee’s guilt of breach of trust or other sufficient cause. Therefore, his acquittal on reasonable doubt did not affect the validity of the dismissal order based on the administrative finding of gross negligence and conduct prejudicial to the company’s interest.