G.R. No. L-74187. January 28, 1988.
Stanford Microsystems, Inc., petitioner, vs. National Labor Relations Commission and Henry Trinio, respondents.

FACTS

Henry Trinio, employed as a security coordinator by Stanford Microsystems, Inc., was dismissed after a company investigation found him guilty of serious breaches of company rules on July 4, 1982. The investigation established that Trinio allowed two female security guards into the Security Office, introduced and consumed intoxicating liquor on the premises, invited another on-duty guard to drink, and subsequently engaged in sexual intercourse with one of the female guards on the office desk while the other pretended to sleep.
Trinio filed a complaint for illegal dismissal. The Labor Arbiter, while finding Trinio guilty of serious misconduct and acts “repulsive to morality,” ruled that dismissal was too severe. Citing the company’s own rules, the Arbiter held that the prescribed penalty for such infractions was suspension not exceeding thirty days. He thus ordered Trinio’s reinstatement with backwages. The National Labor Relations Commission (NLRC) affirmed the reinstatement order but limited the backwages to two years.

ISSUE

Whether the NLRC committed grave abuse of discretion in affirming the Labor Arbiter’s order for reinstatement, despite the finding that Trinio was guilty of serious misconduct, on the ground that the company’s rules prescribed only suspension.

RULING

Yes, the NLRC committed grave abuse of discretion. The Supreme Court granted the petition and upheld the dismissal as valid. The legal logic centers on the principle that an employer’s prerogative to dismiss an employee for serious misconduct is not strictly limited to the literal penalties enumerated in its company rules. While company rules provide guidelines, they cannot operate to negate the employer’s right to impose a heavier penalty like dismissal when the facts, as established, constitute serious misconduct under the Labor Code.
The Court found that Trinio’s actions—drinking liquor on duty, sanctioning rule violations by subordinates, and publicly performing an adulterous act on company property—transcended mere infractions. As the security coordinator, his conduct demonstrated a profound lack of morals, respect for company rules, and appreciation for his responsibility, thereby betraying the trust reposed in him. The argument that these were “first offenses” or did not cause direct financial prejudice was immaterial. The employer cannot be compelled to retain an employee whose actions so plainly reveal depravity and contempt for his duties. The concern for labor rights cannot justify disregarding the employer’s right to protect its interests and integrity from an employee’s grossly immoral and scandalous behavior. The decisions of the Labor Arbiter and NLRC were annulled, and Trinio’s complaint was dismissed.