Philippine Long Distance Telephone v. Domingo
REITERATIONFacts
The Antecedents: Respondent Cecilio Z. Domingo was employed by petitioner Philippine Long Distance Telephone Company (PLDT) as an Installer/Repairman since 1980 and later became a permanent Storekeeper in 2001. In 2002, PLDT observed a drastic increase in materials requisitioned from its warehouses, specifically through PLD 140 and PLD 158 forms, amounting to P17,081,843.31, a significant jump from P1,069,285.36 in 2001. A subsequent inventory revealed a huge discrepancy between requisitioned materials and those actually used or remaining. An investigation indicated that signatures on many requisition forms were forged, and warehouse personnel identified Domingo as the individual who presented these forged forms and received the materials. Clerks also stated that Domingo instructed them to prepare these forged forms. Due to these findings, PLDT initiated an administrative investigation against Domingo for serious misconduct. Procedural History: PLDT issued three invitations to Domingo for a formal inquiry regarding the anomalous transactions, all of which he refused to acknowledge or attend. Consequently, PLDT proceeded with its investigation and issued a Request for Explanation to Domingo, detailing the alleged fraudulent requisitions and material losses. Domingo submitted a written explanation denying the allegations. Following a review, PLDT issued a Notice of Termination, dismissing Domingo for serious misconduct. Aggrieved, Domingo filed a complaint for illegal dismissal. The Labor Arbiter dismissed his complaint, finding substantial evidence of Domingo's involvement in the fraudulent transactions. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. Domingo then filed a Petition for Certiorari with the Court of Appeals (CA), which granted the petition, declared Domingo illegally dismissed, and ordered his reinstatement with backwages. PLDT sought reconsideration, which was denied, leading to the present petition. The Petition: Petitioner PLDT filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. PLDT argues that the CA committed a serious error in giving due course to Domingo's petition for certiorari, as he failed to establish grave abuse of discretion by the NLRC. PLDT contends that the NLRC's findings were supported by substantial evidence, that Domingo was not denied due process, and that his dismissal for serious misconduct was valid. PLDT asserts that the CA erred in annulling the NLRC's resolution, ordering reinstatement, and awarding backwages and attorney's fees, as the NLRC correctly found that Domingo was validly dismissed based on the evidence presented, including testimonial and documentary evidence, and that procedural due process was observed through ample opportunity to be heard, even without a formal hearing. PLDT also argues that the offense was not condoned and that the technical rules of evidence, including the necessity of cross-examination, are not strictly applied in labor cases.
Issue(s)
Whether the Court of Appeals committed serious error in giving due course to Domingo's Petition for Certiorari, notwithstanding the fact that he was not able to establish grave abuse of discretion amounting to lack or excess of jurisdiction that would justify the nullification of the Decision of the National Labor Relations Commission. Whether the NLRC committed grave abuse of discretion in finding that the charges against Domingo have not yet been condoned. Whether the NLRC erred when it considered the First, Second, and Third Invitations as the "show cause" notices contemplated in the CBA. Whether the NLRC committed grave abuse of discretion when it held that Domingo was validly dismissed, considering that PLDT presented no proof that Domingo was properly furnished with copies of the same; and whether procedural due process was observed, considering that no hearing or conference was conducted, and Domingo was not furnished with copies of the investigative findings, nor was he confronted with all of the evidence against him. Whether the NLRC committed grave abuse of discretion in finding that PLDT was able to demonstrate by substantial evidence Domingo's participation in the falsification of the forged PLD forms. Whether the right to cross-examine is indispensable for due process, and whether the NLRC erred in admitting photocopied documents. Whether the Court of Appeals erred in reversing the NLRC's findings and ordering reinstatement, backwages, and attorney's fees.
Ruling
The Supreme Court granted the Petition, reversed and set aside the Decision and Resolution of the Court of Appeals, and reinstated the Resolution of the National Labor Relations Commission. The Court found that the NLRC did not commit grave abuse of discretion in affirming the LA's findings that Domingo's dismissal was valid. Consequently, the CA's grant of reinstatement, backwages, and attorney's fees was overturned.
Ratio Decidendi
On the CA's review of NLRC findings: The Court reiterated that findings of fact of quasi-judicial agencies like the NLRC must be accorded great respect and finality when supported by substantial evidence. The CA's jurisdiction under Rule 65 is limited to reviewing issues of want or excess of jurisdiction and grave abuse of discretion, not the correctness of the evaluation of evidence. The Court found no grave abuse of discretion on the part of the NLRC to justify the CA's modification and reversal of its factual findings, as the NLRC judiciously reviewed the records and based its ruling on substantial evidence. On condonation of the offense: The Court disagreed with Domingo's claim that the offense was condoned under the CBA. It noted that PLDT's delay in issuing the Request for Explanation was partly due to Domingo's own fault in refusing to cooperate with the investigation by refusing to receive the three invitations to formal inquiries. These invitations were considered akin to the "show cause" memorandum required by the CBA. On the 'show cause' notices: The Court considered the First, Second, and Third Invitations as akin to the "show cause" memorandum required by the CBA, due to Domingo's refusal to cooperate with the investigation. On procedural due process: The Court found that Domingo was not denied due process. Procedural due process requires two written notices and an opportunity to be heard. PLDT provided Domingo with a Request for Explanation (first notice) detailing the charges and an opportunity to explain his side, and a Notice of Termination (second notice) informing him of the dismissal. Domingo responded to the Request for Explanation, and the opportunity for a hearing was offered, which he did not avail of. The Court clarified that a formal hearing is not a sine qua non for due process; an ample opportunity to be heard is sufficient. On the quantum of proof in illegal dismissal cases and Domingo's defense: The Court emphasized that the quantum of proof required in illegal dismissal cases is merely substantial evidence, defined as relevant evidence that a reasonable mind might accept as adequate to support a conclusion. For serious misconduct, the employer must prove with substantial evidence that the acts were of a serious nature, related to the employee's duties, and rendered the employee unfit to continue working for the employer. Both the LA and NLRC found that PLDT presented substantial evidence, including numerous witnesses and documentary evidence, to prove Domingo's involvement in fraudulent requisitions using forged PLD forms, which were unaccounted for. The possession and use of these forged forms created a presumption of involvement. The Court found Domingo's defenses of bare denials and claims of merely following instructions unconvincing. Despite not receiving formal training, Domingo had been a Storekeeper since May 2001 and was aware of the normal volume of transactions. The drastic increase in requisitions in 2002, which he was personally involved in, made his claim of ignorance or mere compliance with instructions incredible. His acts of knowingly using forged PLD forms, which cost PLDT P17,115,796.34, related to his duties as Storekeeper, and demonstrated his unfitness to continue employment due to loss of trust and confidence. On the right to cross-examine: The Court reiterated that the technical rules of evidence are not strictly applied in labor cases. While cross-examination is ideal, it is not indispensable for due process. The essence of due process is the opportunity to be heard and to explain one's side. The Court cited jurisprudence holding that administrative bodies are not bound by technical niceties and that the opportunity to be heard is paramount, not necessarily the opportunity to cross-examine. The Court also noted that the relaxed application of evidence rules extends to the admission of photocopied documents in labor cases. On the CA's reversal: The Court found no grave abuse of discretion on the part of the NLRC to justify the CA's modification and reversal of its factual findings, as the NLRC judiciously reviewed the records and based its ruling on substantial evidence.
Main Doctrine
The Court of Appeals may reverse and modify the findings of fact of the NLRC only if grave abuse of discretion exists. In illegal dismissal cases, the quantum of proof required is merely substantial evidence. Procedural due process requires two written notices and an opportunity to be heard, but not necessarily a formal hearing. The technical rules of evidence need not be strictly applied in labor cases.