Manila Press, Inc. v. Inciong
REITERATIONFacts
The Antecedents: Mariano Rodrigo, a laborer of Manila Press, Inc., was caught by a security guard carrying ten envelopes while leaving the compound. He was subsequently charged with frustrated theft, convicted, and his conviction became final. Procedural History: In an attempt to exculpate Rodrigo, four co-employees, Ricardo Cajucom, Rogelio Roldan, Felix Lozano, and Marcelino Perucho, executed a joint affidavit claiming the factory supervisor gave Rodrigo permission to take the envelopes, which the supervisor denied. Manila Press, Inc. filed a complaint for perjury against Cajucom, Roldan, Lozano, and Perucho. The city court convicted Cajucom of perjury, but his appeal was not perfected. Roldan and Perucho appealed their conviction, and the Court of Appeals acquitted them on the ground of reasonable doubt. The Petition: Manila Press, Inc. filed an application for clearance to terminate the employment of Cajucom, Roldan, Lozano, and Perucho. Subsequently, Manila Press, Inc. terminated the services of Cajucom and Roldan. Cajucom and Roldan filed a complaint for illegal dismissal, unfair labor practice, and non-payment of sick and vacation leaves. The Labor Arbiter ordered their reinstatement with backwages. The National Labor Relations Commission affirmed this decision, and the Deputy Minister of Labor affirmed the NLRC's decision. The Supreme Court reviewed the dismissal of Cajucom and Roldan.
Issue(s)
Whether the dismissal of Ricardo Cajucom was proper. Whether the dismissal of Rogelio Roldan was proper, considering his acquittal by the Court of Appeals on the ground of reasonable doubt and his plea for compassionate justice.
Ruling
The judgment of the National Labor Relations Commission dismissing Ricardo Cajucom is affirmed, but the dismissal of Rogelio Roldan is reversed and set aside. Manila Press, Inc. is ordered to reinstate Rogelio Roldan immediately to his former position or to any other similar job. No costs.
Ratio Decidendi
On the dismissal of Ricardo Cajucom: The Court held that the dismissal of Ricardo Cajucom was proper. The labor agencies acted with grave abuse of discretion amounting to lack of jurisdiction in ordering his reinstatement. Cajucom committed perjury to favor a fellow employee, which constitutes misconduct. This fact was admitted by the Solicitor General. Therefore, his termination from employment was justified based on his proven misconduct. On the dismissal of Rogelio Roldan: The Court found that while a conviction in a criminal case is not indispensable to warrant an employee's dismissal, the circumstances surrounding Roldan's case warranted a different outcome. Roldan was ultimately acquitted by the Court of Appeals on the ground of reasonable doubt. Considering Roldan's plea for compassion, detailing his family's abject poverty and his own suffering due to lack of food and premature aging, the Court believed that the ends of justice would be served by allowing his reinstatement. However, due to the initial commission of perjury, reinstatement was granted without backwages.
Main Doctrine
While conviction in a criminal case is not indispensable for dismissal, an employer's dismissal of an employee for misconduct, such as perjury, may be deemed improper if the employee is subsequently acquitted on reasonable doubt, especially when considering pleas for compassion, though reinstatement without backwages may be granted in such circumstances.