GR L 70608; (December, 1987) (Digest)
G.R. No. L-70608 December 22, 1987
ALLIED BANKING CORPORATION, petitioner, vs. RICARDO C. CASTRO, CECILIO T. SENO, FEDERICO O. BORROMEO, in their capacity as COMMISSIONERS OF NATIONAL LABOR RELATIONS COMMISSION (Second Division), DIVINA RANA and DIANA A. SURATOS, respondents.
FACTS
Private respondents Divina Rana and Diana Suratos were employed as bank tellers by petitioner Allied Banking Corporation at its Cagayan de Oro City branch. Following a formal investigation, the bank terminated their employment on November 11, 1982, having found them guilty of several infractions. These included incurring a series of cash shortages and overages, violating procedures for verifying signatures and obtaining approvals before encashing checks over the counter, and failing to follow instructions to report to the Central Bank Cash Units. The employees admitted to these violations.
Rana and Suratos filed a complaint for illegal termination. The Labor Arbiter found the infractions proven but deemed dismissal too severe, ordering instead a one-month suspension and reinstatement with backwages. The National Labor Relations Commission (NLRC) modified this decision on appeal, affirming the suspension and ordering reinstatement with full backwages from December 11, 1982, until actual reinstatement. Allied Bank challenged this NLRC resolution via certiorari.
ISSUE
Whether the NLRC committed grave abuse of discretion in ordering the reinstatement of employees who were admittedly guilty of serious, repeated infractions directly related to their fiduciary duties as bank tellers.
RULING
Yes. The Supreme Court granted the petition, reversing and setting aside the NLRC resolutions. The legal logic is anchored on the fundamental principle of proportionality in labor discipline. While the state policy is to afford protection to labor, this protection does not extend to employees guilty of wrongdoing prejudicial to the employer’s interests. The infractions committed by Rana and Suratos were not minor or isolated; they were serious, repeated violations of core banking procedures essential to maintaining integrity and security in financial transactions.
As bank tellers, the respondents held positions of utmost trust. Their duties involved the handling of cash and strict adherence to verification protocols to prevent fraud and loss. The series of shortages, overages, and procedural breaches demonstrated a pattern of negligence and disregard for rules that directly undermined the employer’s trust and operational safety. In such cases, the employer’s right to dismiss an employee for just cause is paramount. The NLRC’s substitution of its judgment to impose a lesser penalty constituted a grave abuse of discretion, as it disregarded the nature of the offenses and the loss of trust and confidence, which is a valid ground for termination under the Labor Code. The Court upheld the bank’s prerogative to impose the ultimate penalty of dismissal.