Celis v. Bank of Makati
REITERATIONFacts
1. The Antecedents: Respondent Bank of Makati hired petitioner Nancy Claire Pit Celis as an Account Officer in 2013, later reassigning her to Administrative Officer in 2016. Towards the end of 2017, the bank received a report that petitioner had been previously employed at the Rural Bank of Placer and was involved in an embezzlement case, information she had not disclosed in her application. The bank issued a notice of explanation and placed her under preventive suspension. Petitioner admitted to omitting her prior employment, attributing it to excitement, and denied involvement in any embezzlement, calling it hearsay. The bank proceeded to terminate her employment, citing violation of the Code of Conduct for giving false information and serious misconduct, fraud, or willful breach of trust, also considering two prior disciplinary actions against her in 2016: a 10-day suspension for improper conduct and disrespect, and a 15-day suspension for personal borrowing from clients. 2. Procedural History: Following her termination, petitioner filed a complaint for illegal dismissal, monetary claims, and damages, alleging her dismissal was a result of her discovery of corrupt practices within the bank. The Labor Arbiter ruled in favor of the petitioner, finding her dismissal illegal and ordering back wages, separation pay, and attorney's fees. The respondent bank partially appealed to the National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's decision, dismissing the appeal. The NLRC reasoned that petitioner merely withheld information, which did not constitute the offense of knowingly giving false or misleading information. The respondent's motion for reconsideration was denied. Subsequently, the Court of Appeals (CA) reversed the NLRC's decision, finding grave abuse of discretion and upholding the validity of the dismissal, citing the violation of the Code of Conduct and the principle of totality of infractions. The CA denied the petitioner's motion for reconsideration, leading to the present petition. 3. The Petition: Petitioner seeks review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. The core issue is whether the respondent bank validly dismissed petitioner from employment. Petitioner argues that the CA erred in finding grave abuse of discretion by the NLRC. She contends that her omission to disclose past employment was not an act of giving false information, but a mere omission not covered by the bank's Code of Conduct. Furthermore, she argues that the principle of totality of infractions was misapplied, as her previous offenses were not related to the alleged subsequent infraction. The Supreme Court agreed to review the case due to conflicting findings of fact between the labor tribunals and the CA, and to determine if the CA correctly assessed the NLRC's actions for grave abuse of discretion. The Court ultimately found that petitioner was illegally dismissed, reinstating the NLRC's decision with modifications regarding monetary awards and legal interest.
Issue(s)
Whether respondent Bank of Makati validly dismissed petitioner Nancy Claire Pit Celis from employment, and whether her preventive suspension was unjust. Whether the Court of Appeals erred in imputing grave abuse of discretion on the part of the NLRC. Whether petitioner is entitled to monetary awards, including backwages, separation pay, and attorney's fees, and whether moral and exemplary damages are warranted.
Ruling
The petition is GRANTED. The Decision dated June 7, 2019 and the Resolution dated December 6, 2019 of the Court of Appeals are REVERSED and SET ASIDE. The Decision dated July 13, 2018 and the Resolution dated October 26, 2018 of the National Labor Relations Commission are REINSTATED with MODIFICATION that the total monetary award in favor of petitioner shall earn legal interest at the rate of 6% per annum from the date of finality of this Decision until full satisfaction. The case is REMANDED to the Labor Arbiter for the proper computation of the monetary awards.
Ratio Decidendi
On the validity of the dismissal and preventive suspension: The Court held that the respondent Bank of Makati did not have a just cause to dismiss petitioner Nancy Claire Pit Celis. The alleged violation of the Bank's Code of Conduct for "knowingly giving false or misleading information in applications for employment as a result of which employment is secured" was not sufficiently proven. The Court clarified that an omission to disclose a previous employment, as in this case, is not equivalent to "giving false or misleading information." Petitioner merely omitted to state her past employment with the Bank of Placer, and there was no overt or positive act of providing false information. Furthermore, the Bank of Placer allowed petitioner to exit without any derogatory record, and there was no evidence that she was implicated in any embezzlement case thereat. The Court emphasized that doubts in the interpretation of labor legislation and contracts, as well as in the appreciation of evidence in labor cases, should be resolved in favor of labor, adhering to the constitutional policy of protection to labor. The Court found petitioner's 30-day preventive suspension to be unjust because her omission to declare a previous employment did not pose a serious and imminent threat to the employer's life or property. Consequently, the NLRC did not commit grave abuse of discretion in affirming the LA's ruling that petitioner was entitled to full backwages computed from the time of her preventive suspension. The Court also found the CA's reliance on the Principle of Totality of Infractions to be misplaced, as petitioner committed no subsequent violation related to the alleged dishonesty. On the CA's imputation of Grave Abuse of Discretion: The Court found that the CA erred in imputing grave abuse of discretion on the part of the NLRC. The NLRC's findings, which were affirmed by the Supreme Court, were supported by substantial evidence, and the CA's reversal was based on a misapplication of legal principles, particularly the totality of infractions rule and the interpretation of "giving false or misleading information." On Monetary Awards: The Court affirmed petitioner's entitlement to full backwages and separation pay in lieu of reinstatement due to strained relations between the parties, stemming from petitioner's allegation that her dismissal was precipitated by her discovery of corrupt practices. The Court noted that while the allegations of corrupt practices were not established, the existing antagonism made reinstatement not in the best interest of the parties. Petitioner was also awarded attorney's fees at 10% of the total monetary award for having been compelled to litigate. However, moral and exemplary damages were denied, as the dismissal, though invalid, was made in an honest but mistaken belief of a just cause, not in bad faith or malevolent manner.
Main Doctrine
An employee's omission to disclose a previous employment in a job application, without more, does not constitute "knowingly giving false or misleading information" under the employer's Code of Conduct, especially when the previous employment did not result in any derogatory record. Furthermore, the principle of totality of infractions cannot be applied if the prior offenses are not related to the subsequent offense upon which termination is decreed, or if no subsequent offense was committed.