G.R. No. L-48814 June 27, 1985
REYNOLDS PHILIPPINE CORPORATION, petitioner, vs. GENARO A. ESLAVA, Technical Assistant of the Office of the President; ACTING SECRETARY OF LABOR AMADO G. INCIONG and PEDRO S. DE JESUS, respondents.

FACTS

Petitioner Reynolds Philippine Corporation dismissed its concurrent Personnel Manager and Government and Public Relations Manager, respondent Pedro S. de Jesus. The dismissal stemmed from an investigation by the company’s Executive Committee, which found that De Jesus had committed acts of malfeasance and misfeasance. The evidence indicated that De Jesus was the author, or at least a participant in the drafting, of several anonymous letters that were highly critical of the company’s Executive Vice-President and General Manager, W. W. Dunkum, Jr. These letters accused Dunkum of mismanagement, inefficiency, and being anti-Filipino. Furthermore, De Jesus prepared a “guide” for the union president to use in a presentation to the board of directors, drafted a union letter to the company’s headquarters in the United States requesting Dunkum’s recall, and facilitated a union telex with the same demand, all without disclosing his involvement to management. When initially questioned, De Jesus denied any complaints against Dunkum.

ISSUE

The core issue is whether the dismissal of Pedro S. de Jesus, a managerial employee, was valid.

RULING

Yes, the dismissal was valid. The Supreme Court reversed the order of the Regional Director of the Department of Labor, which had directed the reinstatement of De Jesus with full backwages. The legal logic rests on the nature of De Jesus’s position and the cause for his termination. As a managerial employee, defined under the Labor Code as one vested with powers to effectively recommend managerial actions such as hiring and discipline, De Jesus occupied a position of trust and confidence. The law recognizes that loss of confidence constitutes a just cause for the dismissal of such employees. The Court found that the company’s Executive Committee had ample basis to lose trust in De Jesus. His actions—secretly authoring or polishing derogatory letters against a top executive, orchestrating union actions to undermine management, and initially denying his participation—demonstrated a clear lack of candor and loyalty. These acts amounted to misfeasance and a breach of the trust reposed in him as a key member of the management team. The Court emphasized that when an employer has sufficient reason to distrust a managerial employee, the labor tribunal cannot justly deny the employer the authority to dismiss that employee. The investigation conducted by the company, which evaluated documentary evidence and De Jesus’s own answer, provided substantial basis for the finding of breach of trust, thereby validating the dismissal.