Ramirez v. Suerte Steel Corporation
REITERATIONFacts
1. The Antecedents: Emelita A. Ramirez, employed as a sales clerk by Suerte Steel Corporation, was accused of dishonesty for accepting money from a customer and selling company metal scraps without proper authorization. The company alleged this violated their policy on dishonesty and constituted a breach of trust, leading to her termination. 2. Procedural History: Ramirez filed a complaint for illegal dismissal, which the Labor Arbiter initially ruled in her favor, ordering reinstatement and backwages. However, the National Labor Relations Commission (NLRC) reversed this decision, finding the dismissal lawful. The Court of Appeals subsequently denied Ramirez's petition for certiorari, upholding the NLRC's ruling and her dismissal. 3. The Petition: Ramirez filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision. She argued that her dismissal was illegal and that she was deprived of due process. The Supreme Court, however, denied the petition, affirming the appellate court's findings that Ramirez committed serious misconduct and breached the trust reposed in her by the company, thus justifying her termination.
Issue(s)
Whether petitioner Emelita A. Ramirez was illegally dismissed from employment. Whether petitioner was deprived of due process.
Ruling
The petition is DENIED and the assailed Decision of the Court of Appeals is AFFIRMED. Petitioner Emelita A. Ramirez was not illegally dismissed.
Ratio Decidendi
On the issue of illegal dismissal: The Court affirmed the findings of the Court of Appeals that petitioner violated Company Policy No. V (par. 4) on dishonesty. Petitioner, as a sales clerk, was tasked with selling steel tubes and scrap metal, handling customer payments, and depositing them to the company account. Crucially, she did not have the authority to sell scrap metal without prior approval from the Operations-in-Charge, Carmela C. Golozino. However, petitioner sold scrap metal on July 10, 1997, without obtaining the necessary approval. This act constituted serious misconduct or willful disobedience of the lawful orders of her employer, as well as a willful breach of the trust reposed in her. Article 282 of the Labor Code, as amended, provides that an employer may terminate employment for serious misconduct, willful disobedience, or fraud or willful breach of trust. Therefore, the termination of petitioner's employment was in order. On the issue of due process: The Court found no merit in petitioner's contention that she was deprived of due process. The records did not contain any evidence to sustain this claim. The Court reiterated the well-established rule that findings of fact by the Court of Appeals are conclusive on the parties and are not reviewable by the Supreme Court, emphasizing that reviewing such findings is not a function the Supreme Court normally undertakes.
Main Doctrine
An employee's act of profiting from a transaction without proper authority constitutes serious misconduct and willful breach of trust, justifying termination from employment. The findings of fact by the Court of Appeals are conclusive on the Supreme Court.