G.R. No. L-52034 September 27, 1988
SALVADOR LACORTE, petitioner, vs. HON. AMADO G. INCIONG, HON. FRANCISCO L. ESTRELLA, and ASEAN FABRICATORS, INC., respondents.

FACTS

Petitioner Salvador Lacorte was employed as a warehouseman by private respondent Asean Fabricators, Inc. On January 19, 1977, he purchased scrap materials from the company. When attempting to remove the purchased items, he was stopped by a security guard. An investigation allegedly revealed that the items weighed more than what was invoiced and contained brand new, usable parts, not just junk. The company filed a criminal complaint for qualified theft, which was later dismissed by the fiscal for insufficiency of evidence. Subsequently, the company filed an application for clearance to terminate Lacorte’s employment on grounds of loss of trust and confidence.
The Labor Regional Director granted the application for clearance, finding that Lacorte, by his acts, breached the trust reposed in him as a warehouseman. This order was affirmed by the Deputy Minister of Labor. Lacorte filed this special civil action for certiorari and mandamus, arguing the orders were issued with grave abuse of discretion and violated his due process. He contended the dismissal of the criminal case negated loss of confidence, the delay in filing the application suggested a different motive (his union activities), and he was unaware of the post-incident weighing of the materials.

ISSUE

Whether public respondents acted with grave abuse of discretion in granting the application for clearance to terminate petitioner’s employment based on loss of trust and confidence.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The Court clarified that the quantum of evidence required in administrative labor cases is substantial evidence, which differs from the proof beyond reasonable doubt needed in criminal cases. Therefore, the fiscal’s dismissal of the theft complaint was not binding on the labor tribunal. The labor officials correctly appreciated the facts, noting Lacorte held a fiduciary position, and his actions provided substantial basis for a genuine loss of confidence.
On the procedural due process claim, the records showed Lacorte was afforded ample opportunity to present his case through hearings and position papers. His affidavits alleging union motivation were filed only after the case was submitted for decision, explaining their omission from the initial order. The alleged delay in filing the termination application was reasonably attributed to the company’s internal investigation. Factual findings of administrative agencies, when supported by substantial evidence, are accorded respect and finality. The Court found such substantial evidence supporting the conclusion that Lacorte’s acts breached the trust essential to his employment, justifying dismissal.