Facts:

The case involves Reynaldo Q. Agullano as the petitioner and Christian Publishing, represented by its owner Catalina Leonen Pizarro, as the respondents. The events leading to the case began on February 15, 1999, when Agullano was hired as a printing manager by Christian Publishing, with a monthly salary of P11,000. His responsibilities included attending meetings with prospective clients and participating in printing organization meetings. On March 30, 2000, Agullano failed to attend a pre-bidding meeting at the Department of Education, Culture and Sports (DECS) and a general membership meeting of the Printing Industries Association of the Philippines (PIAP). In response, the Human Resources Department Coordinator, Ms. Venus F. Barnuevo, issued a memorandum requiring Agullano to explain his absence within 24 hours. Agullano submitted an explanation, apologizing for forgetting the meetings and citing a transport strike as the reason for his tardiness.

On July 25, 2000, the r...

Facts:

Employment and Appointment

• On February 15, 1999, respondent Christian Publishing, a single proprietorship owned by Catalina Leonen Pizarro, hired petitioner Reynaldo Q. Agullano as printing manager with a monthly salary of P11,000.00.
• As printing manager, petitioner’s duties included meeting prospective clients and attending meetings of printing organizations.

Incidents Leading to Disciplinary Action

• On March 30, 2000, petitioner failed to attend two important meetings: a pre-bidding meeting at the Department of Education, Culture and Sports (DECS) and the general membership meeting of the Printing Industries Association of the Philippines (PIAP).
• On the same day, respondent’s HRD Coordinator, Ms. Venus F. Barnuevo, issued a memorandum requiring petitioner to submit an explanation for his absences within 24 hours upon receipt.
• Petitioner responded by submitting a letter in which he apologized and explained that he had forgotten the engagements, attributing his delay to an on-going transport strike and an issue with his attire.

Subsequent Accusations and Termination

• On July 25, 2000, respondent sent a memorandum highlighting petitioner’s habitual absences and tardiness, specifically noting:
• Absences from July 3-8, 2000; July 12, 22, and 24, 2000; and several Saturday absences in May and June 2000.
• A statement that, due to the company’s financial situation, employees who compounded the burden with such behavior could no longer be tolerated.
• On July 26, 2000, respondent terminated petitioner’s employment through a termination letter listing the following grounds:
• Habitual absences and tardiness, including those on DECS and PIAP meeting dates.
• The breach of company rules despite previous verbal warnings.

Legal Proceedings and Administrative Actions

• Petitioner filed a complaint with the National Labor Relations Commission (NLRC) alleging illegal dismissal and seeking damages.
• On February 28, 2002, the Labor Arbiter declared the dismissal illegal but ordered respondents to pay separation pay (one month’s salary per year of service), service incentive leave pay for five days, and pro-rated 13th month pay.
• Dissatisfied with the Labor Arbiter’s decision, petitioner appealed to the NLRC, which on January 22, 2003, modified the decision by ordering the payment of full backwages and other benefits (while dismissing the other claims).
• Respondents sought reconsideration of the NLRC ruling, but it was denied on May 6, 2003.
• Respondents filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA), alleging grave abuse of discretion on the part of the NLRC.
• On October 29, 2003, the CA annulled the decisions of both the NLRC and the Labor Arbiter, thereby declaring petitioner’s dismissal valid.
• A motion for reconsideration was filed by petitioner but was subsequently denied by the CA on July 28, 2004.
• Petitioner then elevated the issue to the Supreme Court through a Petition for Review on Certiorari.

Issue:

Legitimacy of the Dismissal

• Whether the dismissal of petitioner was legally justified based on his alleged gross and habitual neglect and breach of trust as mandated by Article 282 of the Labor Code.
• Whether the substantive grounds cited by the respondent suffice to justify termination.

Compliance with Procedural Due Process

• Whether the twin notice requirement—the issuance of a detailed first notice and a subsequent notice of termination with an opportunity to be heard—was satisfied.
• Whether petitioner was provided a reasonable opportunity to submit his explanation and mount a defense before being dismissed.

Indemnity for Violation of Statutory Rights

• Whether the procedural lapses in notifying and hearing petitioner warrant the imposition of indemnity despite the existence of a just cause for dismissal under substantive law.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)