Malabunga v. Cathay Pacific Steel Corporation
REITERATIONFacts
The Antecedents: Respondent Cathay Pacific Steel Corporation hired petitioner Dominador Malabunga, Jr. as a machinist. An inventory on July 9, 2004, revealed one aluminum level issued to the Fabrication Unit and another to petitioner. Petitioner returned an aluminum level on July 11, 2004. On July 24, 2004, respondent issued a notice charging petitioner with theft of the Fabrication Unit's aluminum level, alleging he stole it and returned it to cover up the loss of his own. Handwritten statements from warehouse foreman Salvador Narvasa and warehouseman Reymundo Manuel Baetiong claimed the returned level was the Fabrication Unit's, identified by markings and a dent, and that petitioner had remarked the Fabrication Unit crew should be blamed for negligence. Petitioner insisted the accusation was false, that he returned the exact tool he borrowed, and argued that respondent's tools should be marked to prevent confusion. He also stated the Fabrication Unit marked its level days after the incident and that the warehousemen accepted his returned tool without complaint. Procedural History: Respondent issued a Decision on December 2, 2004, suspending petitioner for 30 days and requiring him to pay ₱280.00 for the lost aluminum level, finding him guilty of theft. Petitioner's motion for review was denied on February 18, 2005. Petitioner filed a complaint for illegal suspension before the NLRC, which was dismissed by the Labor Arbiter on July 31, 2006, finding substantial evidence warranted the suspension. The NLRC, on February 27, 2009, reversed the Labor Arbiter's decision, finding the affidavits inadequate and that returning the lost item does not create a presumption of theft, ordering Cathay Pacific Steel Corporation to pay petitioner his salary for the suspension period. The NLRC denied respondent's motion for reconsideration. Respondent filed a Petition for Certiorari with the Court of Appeals (CA), which on March 16, 2011, granted the petition, nullified the NLRC decision, and reinstated the Labor Arbiter's decision. Petitioner's motion for reconsideration was denied on September 5, 2011. The Petition: Petitioner seeks to set aside the CA dispositions and reinstate the NLRC's decision, arguing that the evidence does not support the claim of theft and that the witnesses' statements are biased, self-serving, and doubtful.
Issue(s)
Whether the Court of Appeals erred in vacating the decision and resolution of the National Labor Relations Commission finding the respondent corporation guilty of illegal suspension. Whether there was substantial evidence to support the charge of theft against the petitioner, and whether the suspension was illegal.
Ruling
The Petition is GRANTED. The assailed March 16, 2011 Decision and September 5, 2011 Resolution of the Court of Appeals are REVERSED and SET ASIDE, and the February 27, 2009 Decision of the National Labor Relations Commission is REINSTATED and AFFIRMED.
Ratio Decidendi
On the issue of illegal suspension: The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the NLRC decision. The Court found that the employer cannot blame its employees for losses caused by its own systemic failures and that any doubts in the evidence must be resolved in favor of labor, as mandated by the Labor Code. Therefore, the suspension was declared illegal. On the issue of whether there was substantial evidence to support the charge of theft: The Court found that the evidence miserably failed to support a finding that petitioner committed theft. The Court highlighted the contradiction between the claims of the Fabrication Unit workers and the warehousemen. While the Fabrication Unit workers claimed the returned aluminum level had a "Fabrication" engraving and a dent, warehouseman Narvasa categorically declared that what petitioner returned was an "untarnished" (malinis) aluminum level, without any engraving or dent. This directly contradicted the claims of the Fabrication Unit workers. The Court noted that Baetiong, another warehouseman, had no personal knowledge and only learned about the alleged theft from Tercero, who claimed to have discovered the "lost" level in the warehouse. The Court found it illogical for petitioner, if guilty of theft, to return the very object of the crime. Furthermore, the Court pointed out that the alleged loss of the Fabrication Unit's aluminum level was never officially reported, and the workers only declared it lost when Tercero supposedly found it in the warehouse. This indicated a lack of actual loss and made the workers' statements highly doubtful and self-serving. The Court emphasized the respondent's disorganized system and inept personnel in its warehouse operations, citing the lack of security features, proper identification, and efficient monitoring.
Main Doctrine
An employer cannot blame its employees for losses caused by its own disorganized system and inept personnel. Doubts in evidence in labor cases should be resolved in favor of labor.