GR L 63191; (April, 1984) (Digest)
G.R. No. L-63191. April 30, 1984.
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION, NOEL SEVILLA and MELQUIADES ALFONSO, respondents.
FACTS
This case involves a petition to set aside an NLRC decision ordering the reinstatement of two employees, Noel Sevilla and Melquiades Alfonso. The petitioner, PLDT, filed separate applications for clearance to terminate their employment. Alfonso was sought to be dismissed for alleged misappropriation of company properties, while Sevilla was charged with committing fraudulent acts. Both were employed as Cable Splicer Headcrews, with duties involving fieldwork and the requisition of necessary materials, for which they were required to submit daily Plant and Daily Work Reports (PDWRs).
The Supreme Court, in a prior resolution, had already dismissed the petition regarding Alfonso, making his reinstatement final. The present petition proceeded only concerning Sevilla. PLDT’s investigation alleged Sevilla committed specific anomalies: he made a requisition for materials against a fictitious and non-existent work order, as the stated cable number did not correspond to any work reported in his PDWRs for the relevant dates. He also made a double requisition of materials for a work order that, according to his own report, had been completed a day earlier without using any materials.
ISSUE
Whether the termination of Noel Sevilla on the ground of loss of confidence was valid.
RULING
Yes, the termination was valid. Loss of confidence is a valid ground for dismissal under Article 283 of the Labor Code, provided the employee holds a position of trust and there is a sufficient basis for such loss. The Court clarified that proof beyond reasonable doubt is not required; it is sufficient if the employer has reasonable grounds to believe the employee committed an act justifying the loss of trust.
The Court found adequate evidence that Sevilla committed fraud or breach of trust. The discrepancies between his requisition slips and his daily work reports demonstrated deceitful conduct. His actions in requisitioning materials for a fictitious job and making a double requisition for already-completed work constituted a clear breach of the trust inherent in his position, which involved handling company materials and reporting on their use. The dismissal of a related criminal complaint by the fiscal is not binding on labor tribunals. As established in jurisprudence, an acquittal in a criminal case does not preclude valid dismissal if the employer has legitimately lost confidence. Therefore, the NLRC decision was modified, and Sevilla’s termination was sustained.
