International Rice Research Institute v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner International Rice Research Institute (IRRI) hired Nestor B. Micosa as a laborer in 1977. IRRI's Miscellaneous Provisions stated that an employee convicted of a criminal offense involving moral turpitude may be dismissed. On February 6, 1987, Micosa stabbed and killed Reynaldo Ortega. On January 23, 1990, Micosa was convicted of homicide, with the trial court appreciating the mitigating circumstances of incomplete self-defense and voluntary surrender, and finding no aggravating circumstances. Micosa applied for probation, which was granted. Procedural History: IRRI urged Micosa to resign due to his conviction. Micosa refused. IRRI charged him with violating its Personnel Manual for conviction of a crime involving moral turpitude. Micosa explained his conviction arose from self-defense and did not involve moral turpitude. IRRI's Grievance Committee recommended his continued employment, but IRRI terminated his employment on May 21, 1990. Micosa filed a case for illegal dismissal. The Labor Arbiter found the termination illegal and ordered reinstatement with backwages. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision, deleting only the award of attorney's fees. The Petition: IRRI filed a petition for certiorari, arguing that the NLRC gravely abused its discretion in finding that IRRI had no right to prescribe causes for dismissal not enumerated in the Labor Code and in holding that Micosa's conviction for homicide did not constitute moral turpitude under IRRI's Personnel Manual.
Issue(s)
Whether a conviction of homicide constitutes a crime involving moral turpitude warranting dismissal from employment. Whether IRRI had the right to dismiss Micosa based on its internal policy when his conviction was not work-related and did not involve moral turpitude. Whether the NLRC committed grave abuse of discretion in affirming the Labor Arbiter's finding of illegal dismissal.
Ruling
The petition is dismissed for lack of merit. The termination of Micosa's employment was illegal. The NLRC did not commit grave abuse of discretion.
Ratio Decidendi
On the issue of whether conviction of homicide constitutes a crime involving moral turpitude: The Court held that conviction of homicide does not automatically involve moral turpitude. Moral turpitude is defined as everything which is done contrary to justice, modesty, or good morals; an act of baseness, vileness, or depravity in the private and social duties which a man owes his fellowmen, or to society in general, contrary to justice, honesty, modesty, or good morals. The determination of whether a crime involves moral turpitude is for the Supreme Court to decide. In this case, the homicide resulted from an act of incomplete self-defense against unlawful aggression, and the mitigating circumstances of incomplete self-defense and voluntary surrender were appreciated, along with the absence of aggravating circumstances. These facts demonstrated that Micosa's character and intentions were not inherently vile, immoral, or unjust, and that his intention was to defend himself rather than to kill. The Court emphasized that moral turpitude is not involved in every criminal act and depends on the surrounding circumstances. The conviction for homicide, under these specific facts, was not classified as involving moral turpitude. On the issue of whether IRRI had the right to dismiss Micosa based on its internal policy: The Court ruled that IRRI could not terminate Micosa's employment except for justifiable causes as defined by the Philippine Labor Code. Article 282 of the Labor Code enumerates the just causes for termination, and conviction of a crime involving moral turpitude is not explicitly listed. Furthermore, the Court found that the conviction was not work-related, as the crime was committed outside the IRRI complex, after office hours, and against a non-IRRI employee. It did not involve fraud, willful breach of trust, or an offense against the employer or its representatives, as contemplated under Article 282 (c) and (d). IRRI failed to present evidence that Micosa posed a danger to the company or its personnel, and his service record was unblemished. The Court noted that even IRRI's Director General had expressed confidence in Micosa's skills and had confirmed his regular core employee status, assuring termination only for justifiable causes under the Labor Code. On the issue of whether the NLRC committed grave abuse of discretion: The Court found no abuse of discretion on the part of the NLRC. The NLRC affirmed the Labor Arbiter's decision, which correctly found the termination of Micosa's employment to be illegal. The Court reiterated that for certiorari to lie, there must be a capricious, arbitrary, and whimsical exercise of power, which was not demonstrated in this case. The NLRC's decision was based on a thorough review of the facts and applicable law, and its affirmation of the Labor Arbiter's ruling was well-founded.
Main Doctrine
Conviction of homicide, particularly when committed with incomplete self-defense and voluntary surrender, does not automatically constitute a crime involving moral turpitude that warrants dismissal from employment under the Philippine Labor Code, especially when the employment contract assures termination only for justifiable causes defined therein.