Brent Hospital, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Respondent Teresita M. Fernandez was employed by petitioner Zamboanga Brent Hospital (Brent) as a staff nurse and rose through the ranks, eventually becoming acting clinic coordinator. In August 1990, due to faculty resignations, she was offered the position of principal of Brent's School of Midwifery (BSM), which she initially rejected but eventually accepted with the assurance she could return to her former position after one year. BSM had a policy of collecting P350.00 from reviewees for review classes in Manila to cover coordinator's expenses. In May 1993, the Board scrapped the coordinator's fee. Reviewees requested respondent and Mrs. Norma Pada to accompany them to Manila, offering to voluntarily shoulder expenses. Due to time constraints, this arrangement was not communicated to the Board or parents. Petitioner Brent, through its Hospital Administrator Morlito Apuzen, discovered the collection, alleging that respondent demanded P350.00 from each reviewee. Apuzen reported this to the Board, which convened protesting parents. Upon her return, respondent submitted a report of expenses from voluntary contributions. Respondent and Mrs. Pada were terminated for allegedly violating the policy on coordinator's fees. Procedural History: Respondent filed a case for illegal dismissal and damages. The Labor Arbiter declared the dismissal illegal and ordered Brent to pay separation pay, backwages, moral damages, exemplary damages, and attorney's fees. On appeal, the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. Brent's motion for reconsideration was denied. Respondent partially appealed the award of backwages, which was rejected by the NLRC as filed out of time. Petitioners Brent and Apuzen filed the instant petition for certiorari. The Petition: Petitioners argued that the dismissal was for just or authorized cause and that respondent was denied due process. They also contended that the award of damages was without basis and that co-petitioner Morlito Apuzen should not be held liable. They further argued that as a managerial employee, respondent was subject to different termination rules.
Issue(s)
Whether the dismissal of respondent was without just or authorized cause and denied her due process. Whether the award of moral and exemplary damages is with legal or factual basis. Whether petitioner Morlito B. Apuzen should be held liable.
Ruling
The petition is DISMISSED for lack of merit and the assailed resolution is AFFIRMED subject to modifications: (1) deletion of the award of moral and exemplary damages and attorney's fees for want of factual basis; and (2) reversal of the order finding Morlito Apuzen jointly and severally liable with Brent Hospital, Inc.
Ratio Decidendi
On whether the dismissal was without just or authorized cause and denied her due process: The Court held that respondent did not infringe the policy regarding the collection of coordinator's fees. The reviewees themselves requested respondent and Mrs. Pada to accompany them to Manila, and ninety-five reviewees voluntarily agreed to shoulder expenses, amounting to P350.00 per reviewee. Due to time constraints, respondent advised the reviewees to discuss arrangements with their parents. The Board convened a meeting with parents where respondent and Mrs. Pada explained their actions. The dismissal was based on loss of trust and confidence, but this ground must be based on a willful breach of trust and founded on clearly established facts. The allegations that respondent violated policy and took advantage of her position were not established by petitioner. The voluntariness of the payments negated any finding of impropriety. Furthermore, the argument that managerial employees are subject to different termination rules was rejected, citing Midas Touch Food Corp. v. NLRC, which held that the right to security of tenure applies to both rank-and-file and managerial employees. The Court found that respondent was afforded her statutory rights to notice and hearing, and the dismissal was premised on the honest belief of a policy violation, not a wanton, oppressive, or malevolent manner. On whether the award of moral and exemplary damages is with legal or factual basis: The Court found that moral and exemplary damages must be deleted for want of factual basis. Moral damages are recoverable only if the dismissal was attended by bad faith, fraud, or was oppressive or contrary to morals, good customs, or public policy. Exemplary damages require similar circumstances. In this case, the Board conducted an inquiry, respondent was notified of the charges, and she presented her explanation and an itemized account of expenses. The parents' sentiments were divided, and the dismissal was based on an honest belief of policy violation. Therefore, the dismissal could not be characterized as wanton, oppressive, or malevolent. On whether petitioner Morlito B. Apuzen should be held liable: The Court found this issue meritorious and reversed the NLRC's order holding Apuzen jointly and severally liable. Citing MAM Realty Development Corporation v. NLRC, the Court reiterated that a corporation acts through its directors, officers, and employees, and obligations incurred by them as corporate agents are the direct accountabilities of the corporation, not their personal liabilities. Therefore, Apuzen, acting as a corporate agent, could not be held personally liable.
Main Doctrine
Dismissal based on loss of trust and confidence must be founded on clearly established facts and a willful breach of trust, not on the employer's caprices. The constitutional guarantee of security of tenure applies to both rank-and-file and managerial employees.