Manila Electric Company v. Dejan
REITERATIONFacts
The Antecedents: Respondent Herminigildo Dejan, a branch representative of Manila Electric Company (Meralco) in San Pedro, Laguna, was asked to explain an incident where 20 pieces of meter sockets were released from the branch premises and loaded into a Meralco contracted jeep. Dejan admitted releasing the meter sockets because the deposit fees had been paid and the payor, a private electrician, requested their release. Meralco later charged Dejan with unauthorized taking of company property. During a formal investigation, Dejan admitted issuing the meter sockets without authorization, claiming it was an accepted practice. He alleged that a Meralco field representative, Gil Duenas, instructed him to release the items to another private electrician, Estanislao Gozarin, who was acting on behalf of another private electrician, Antonio Depante. Depante corroborated Dejan's account. Meralco terminated Dejan's employment. Procedural History: The Labor Arbiter dismissed Dejan's complaint, upholding Meralco's dismissal as a valid exercise of management prerogative. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter, finding that Dejan's actions did not constitute unauthorized taking or stealing but simple negligence, and ordered reinstatement without backwages but with a one-month suspension. Both parties moved for reconsideration, which the NLRC denied. Both parties filed petitions for certiorari with the Court of Appeals (CA). The CA affirmed the NLRC's finding that Dejan was not guilty of unauthorized taking or stealing but modified the ruling by awarding backwages from separation until reinstatement, less the one-month suspension, considering Dejan was illegally dismissed. The Petition: Meralco filed a petition for review on certiorari, arguing that the CA erred in holding Dejan liable only for simple negligence and in ordering his reinstatement with backwages. Meralco contended that Dejan's actions constituted dishonesty and warranted dismissal, and that the CA misapprehended the facts, particularly Dejan's admission of violating company procedures and his concert with another employee, Duenas, in the unauthorized release of company property.
Issue(s)
Whether the Court of Appeals committed a reversible error in holding that the respondent was liable only for simple negligence and not for serious misconduct, fraud, and willful breach of trust. Whether the Court of Appeals committed a reversible error in awarding backwages despite finding the respondent liable for simple negligence.
Ruling
The petition is granted. The assailed decision and resolution of the Court of Appeals are set aside. The complaint is dismissed for lack of merit.
Ratio Decidendi
On Issue 1: The Supreme Court found that Dejan was liable for serious misconduct, fraud, and willful breach of trust, constituting just causes for termination under Article 282 of the Labor Code. The Court noted that Dejan released 20 meter sockets to a private electrician without written authorization, contrary to company policy. Dejan's justification that it was an accepted practice and that the deposit fees were paid was found unconvincing. The Court highlighted the involvement of Meralco field representative Gil Duenas, who allegedly orchestrated the release and retrieval of the meter sockets, suggesting a scheme to defraud the company. Furthermore, Dejan's claim that the meter sockets were accounted for by Service Identification Numbers (SINs) for Depante's service applications was debunked by evidence showing these SINs pertained to applications already inspected, approved, and installed with meters prior to the release of the meter sockets. This indicated Dejan's intent to mislead the company and give a semblance of regularity to an unauthorized transaction, thereby defrauding Meralco. The Court emphasized that Dejan, as a branch representative, was expected to act with the highest degree of honesty and integrity, and his fraudulent act justified the loss of Meralco's trust and confidence. On Issue 2: The Court found that the CA grossly misapprehended the facts and evidence on record, which justified its review of the CA's findings. The Court disagreed with the CA's conclusion that Dejan was only guilty of simple negligence. The evidence presented, including Dejan's own admissions and the testimonies of other witnesses, pointed towards a deliberate act of misconduct intended to defraud the company. Therefore, the CA's award of backwages, predicated on a finding of illegal dismissal due to simple negligence, was deemed erroneous. The Court reiterated that the law protects laborers but does not authorize the oppression or self-destruction of the employer, and that Meralco could not be compelled to continue employing an individual who had committed serious misconduct and caused a justifiable loss of trust and confidence.
Main Doctrine
An employee who commits serious misconduct, fraud, and willful breach of trust, such as the unauthorized release of company property with intent to defraud the employer, is validly dismissed for cause, and the employer's loss of trust and confidence in such employee is justified.