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...

Facts:

Background of Employment

• Leandro M. Alcantara was employed by the Philippine Commercial and International Bank (PCIB) beginning August 15, 1974.
• Over time, he rose through the ranks, ultimately serving as the branch manager of the Rizal Avenue branch in Manila.
• It is established that prior to the controversy, he had no disciplinary record, and his last basic monthly salary was P43,900.00.

The CTD Transaction and Alleged Misconduct

• On December 12, 1997, a report emerged from a caller regarding Alcantara’s alleged involvement with a syndicate using two Certificates of Time Deposit (CTDs) in illegal transactions.
• On December 23, 1997, petitioner prepared and processed two CTDs amounting to P538,000.00 and P360,000.00; these certificates were signed by him and by Guillerma F. Alcantara (the head of Sales).
• The CTDs were unbooked, and key details (due dates and term) were omitted in the duplicate control copy and in the PCIAV Input Document Copy, raising issues of record falsification.
• Petitioner admitted to processing these CTDs and later claimed that the certificates were not fully recorded because they had already been cancelled.

Grounds for Dismissal and Bank’s Position

• PCIB terminated petitioner on the grounds that he abused the trust reposed in his position as branch manager and falsified bank records in facilitating a transaction reportedly amounting to P538,360,000.00.
• The Bank’s Memorandum cited several evidentiary points, including:
• The processing of irregular CTDs despite knowing they were unfunded.
• Deliberate omission of due dates and terms on duplicate records, suggesting concealment of the improper transaction.
• Acting unilaterally in processing a transaction that lacked proper placement or available funds.

Initiation of Legal Proceedings

• On August 12, 1998, petitioner filed a complaint with the NLRC’s Regional Arbitration Branch alleging illegal dismissal and other labor-related claims such as non-payment of various benefits and allowances, as well as moral and exemplary damages.
• After the inability to reach an amicable settlement, the Labor Arbiter dismissed the complaint for lack of merit on February 1, 2000.
• Petitioner subsequently appealed; however, the NLRC affirmed the decision and dismissed his appeal on March 26, 2001.
• A Motion for Reconsideration before the NLRC was denied on June 20, 2001.

Petition for Certiorari and Subsequent Developments

• Petitioner filed a petition for certiorari under Rule 65 of the Rules of Court with the Court of Appeals, contesting the NLRC’s resolutions and the previous dismissal.
• The Court of Appeals dismissed his petition on September 27, 2001, primarily due to the petitioner’s failure to attach material portions of the NLRC record and other pertinent documents as required by Rule 46 of the Revised Rules of Civil Procedure.
• Petitioner then filed a Motion for Reconsideration, which was also denied on December 20, 2001, because the petition did not substantially comply with the required rules even after his belated submission.

Issue:

Procedural Compliance and the Application of the Rules

• Whether the Court of Appeals should have accepted petitioner’s belated submission of the required documents accompanying his Motion for Reconsideration despite the initial failure to attach them.
• Whether a liberal construction of procedural rules, especially in labor cases where substantial justice is at stake, warranted a relaxation of the strict attachment requirements under Rule 46.

Substantive Validity of Termination

• Whether petitioner’s dismissal from employment was substantively justified given his actions involving the CTDs.
• Whether due process was afforded to petitioner during the bank’s internal administrative procedures—including notice, opportunity to be heard, and the provision of relevant documents.
• Whether there was sufficient substantial evidence to support that petitioner, by falsifying bank records and processing unfunded CTDs, materially breached the trust reposed in him as a branch manager.

Abuse of Discretion and Reversible Errors

• Whether the National Labor Relations Commission (NLRC) and the Labor Arbiter committed reversible errors or abused their discretion in affirming petitioner’s dismissal.
• Whether the failure to award petitioner additional benefits (such as accrued vacation and sick leaves) constitutes a violation of procedural due process in the context of his termination.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)