GR L 52709; (June, 1983) (Digest)
G.R. No. L-52709 June 24, 1983
MANILA PRESS, INC., petitioner, vs. HON. AMADO G. INCIONG, in his capacity as Deputy Minister of Labor, NATIONAL LABOR RELATIONS COMMISSION, RICARDO CAJUCOM and ROGELIO ROLDAN, respondents.
FACTS
The case involves the dismissal of employees Ricardo Cajucom and Rogelio Roldan by Manila Press, Inc. The incident stemmed from the theft conviction of a co-employee, Mariano Rodrigo. In an attempt to exculpate Rodrigo, Cajucom, Roldan, and two others executed a joint affidavit falsely stating that a factory supervisor had given Rodrigo permission to take company envelopes. The employer filed perjury charges against the four affiants.
Cajucom was convicted of perjury, and his conviction became final after he failed to appeal. Roldan was also initially convicted but was later acquitted by the Court of Appeals on the ground of reasonable doubt. Meanwhile, Manila Press applied for and eventually effected the termination of Cajucom and Roldan. The dismissed employees filed a complaint for illegal dismissal.
ISSUE
Whether the dismissals of Ricardo Cajucom and Rogelio Roldan were valid.
RULING
The Supreme Court ruled differently for each employee. For Ricardo Cajucom, the dismissal was upheld as valid. The Court found that the labor agencies committed grave abuse of discretion in ordering his reinstatement. Cajucom’s final conviction for perjury constituted clear misconduct, a just cause for termination under the law. His act of committing falsehood under oath to favor a fellow employee was a breach of trust and a violation of the standards of conduct expected from an employee.
For Rogelio Roldan, the Court ordered his reinstatement but without backwages. While the Court reiterated the legal principle that a criminal conviction is not an absolute prerequisite for a valid dismissal, as an employer may terminate employment based on a reasonable belief of guilt supported by evidence, it granted equitable relief in Roldan’s case. The decision was influenced by Roldan’s plea for compassionate justice, detailing his family’s extreme poverty and his lack of education, which hindered re-employment. His ultimate acquittal by the Court of Appeals on reasonable doubt provided a legal basis for leniency. Thus, the Court balanced the employer’s prerogative with social justice, ordering reinstatement as an act of compassion while denying backwages as a recognition of the initial propriety of the dismissal action given the circumstances.