Case Digest (G.R. No. 151349)
Facts:
The case involves Leandro M. Alcantara as the petitioner and the Philippine Commercial and International Bank (PCIB) as the respondent. Alcantara was employed by PCIB from August 15, 1974, and eventually became the branch manager of its Rizal Avenue branch in Manila. Prior to the events leading to this case, he had no history of disciplinary actions against him. On December 12, 1997, a report was made to PCIB's Customer Care by Romy Espiritu, alleging Alcantara's involvement with a criminal syndicate using two Certificates of Time Deposit (CTDs) for illegal activities. On December 23, 1997, Alcantara prepared two CTDs amounting to P538,000.00 and P360,000.00, which were unbooked and lacked due dates and terms. He was subsequently dismissed for allegedly abusing the trust placed in him and falsifying bank records to facilitate transactions that were detrimental to the bank's interests.
On August 12, 1998, Alcantara filed a complaint for illegal dismissal and oth...
Case Digest (G.R. No. 151349)
Facts:
Employment Background
- Petitioner Leandro M. Alcantara had been an employee of the Philippine Commercial and International Bank (PCIB) since August 15, 1974. He rose through the ranks and eventually became the branch manager of PCIB's Rizal Avenue, Manila branch. Prior to the controversy, he had never been subjected to disciplinary action.
Allegations of Misconduct
- On December 12, 1997, a certain Romy Espiritu reported to PCIB that Alcantara was involved with a syndicate using two Certificates of Time Deposit (CTDs) issued by PCIB for illegal activities.
- On December 23, 1997, Alcantara prepared two CTDs amounting to P538,000.00 and P360,000.00, which were unbooked and lacked due dates and terms. These CTDs were signed by Alcantara and Guillerma F. Alcantara, the head of Sales.
- PCIB alleged that Alcantara falsified bank records to facilitate a transaction amounting to P538,360,000.00, which was prejudicial to the bank's interests. The Bankwide Evaluation Committee (BEC) found that Alcantara processed irregular CTDs, photocopied them knowing they were unfunded, and failed to indicate due dates and terms on the duplicate control copy, thereby concealing the transaction.
Petitioner's Defense
- Alcantara admitted to processing and preparing the CTDs but claimed they were not booked because they were already canceled. He argued that no bank policy prohibited a branch manager from assisting depositors and that the CTDs were promptly canceled due to the clients' failure to provide funds.
Labor Case
- On August 12, 1998, Alcantara filed a complaint with the National Labor Relations Commission (NLRC) for illegal dismissal, illegal suspension, backwages, and other benefits. The Labor Arbiter dismissed the complaint, finding substantial evidence that Alcantara manipulated bank records to facilitate anomalous transactions. The NLRC affirmed this decision.
Court of Appeals Proceedings
- Alcantara filed a petition for certiorari with the Court of Appeals, which dismissed it due to his failure to attach material portions of the NLRC records. His motion for reconsideration was also denied.
Issue:
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Ruling:
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Ratio:
Substantial Compliance with Procedural Rules: The Supreme Court reiterated that procedural rules should be liberally construed to serve the ends of justice, especially in labor cases. Failure to attach required documents does not automatically warrant dismissal if there is subsequent substantial compliance.
Loss of Trust and Confidence: For employees holding positions of trust and confidence, loss of trust is a valid ground for dismissal. The employer need only show substantial evidence of the employee's breach of trust, not proof beyond reasonable doubt.
Due Process in Termination: The essential elements of due process in employee termination are notice and an opportunity to be heard. A trial-type hearing is not required, and the employer's compliance with these elements suffices.
Finality of Decisions: The Court emphasized that once a decision becomes final and executory, it can no longer be altered, except in exceptional circumstances.
Disposition
The Supreme Court denied Alcantara's petition. The Court of Appeals' resolutions were reversed, but the NLRC's decision affirming Alcantara's valid termination was upheld. No costs were awarded.