G.R. No. 50321. March 13, 1984.
SAN MIGUEL CORPORATION, Petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION, MANUEL R. ENRIQUEZ and FERNANDO CAPIO, Respondents.

FACTS

Manuel Enriquez, a budget clerk, and Fernando Capio, an accounting clerk, were employees of San Miguel Corporation’s Metal Closure and Lithography Plant. An internal audit revealed that a total of P307,303.53 in cash remittances from sales and scrap metal, which were supposed to be delivered to the Makati Head Office, had not been received by the Cash Department. The investigation pointed to Enriquez and Capio as the personnel responsible for the physical delivery and deposit of these funds. Specifically, evidence indicated that various sums were entrusted to them by the plant cashier and storeroom personnel, but these amounts never reached their intended destination.
The company sent demand letters to the employees for restitution and filed applications for clearance to terminate their services, placing them under preventive suspension. The employees filed a complaint for illegal dismissal. The Labor Arbiter found the dismissals valid, but the NLRC reversed this decision, ordering reinstatement with backwages. The NLRC gave weight to the dismissal of related criminal charges by the fiscal for insufficiency of evidence. San Miguel Corporation elevated the case to the Supreme Court.

ISSUE

Whether the dismissal of respondents Enriquez and Capio by San Miguel Corporation was valid based on loss of trust and confidence.

RULING

Yes, the dismissal was valid. The Supreme Court reversed the NLRC decision and reinstated the Labor Arbiter’s ruling. The legal logic centers on the nature of employment involving trust and confidence. The respondents held positions that necessarily involved fiduciary responsibility, as they had direct custody and control over company funds for delivery. Proof beyond reasonable doubt, as required in criminal cases, is not the standard for terminating employment on the ground of loss of trust and confidence. It is sufficient that the employer has reasonable grounds to believe that the employee is responsible for the misconduct.
The Court found that the company presented substantial evidence, including witness testimonies and discrepancies in transmittal slips, to establish a reasonable basis for its loss of confidence. The disappearance of a critical logbook and the forgery of signatures on remittance slips further supported the finding of misconduct. The dismissal of the criminal case by the fiscal, being merely recommendatory and based on a different standard of proof, does not preclude a finding of just cause for dismissal in labor proceedings. An employer has the right to dismiss employees for acts inimical to its interests when trust is breached. Therefore, the company validly exercised its management prerogative to terminate the employment of Enriquez and Capio.