Facts:

The case involves Edgardo B. Alcazaren as the petitioner against Univet Agricultural Products, Inc. as the respondent. Alcazaren commenced employment with Univet as a casual employee in 1982, eventually rising to the position of sales supervisor for the West Visayas Area by November 1994. On July 3, 1996, he was transferred to the East Visayas Area, but he refused to acknowledge the inter-office memorandum communicating this change. Alcazaren was ordered to attend sales meetings scheduled on July 15 and 16, 1996, but he failed to attend, citing the death of his grandmother and his subsequent obligations as a reason for his absence. After multiple directives from management, including a requirement to explain his absence within specified time frames, Alcazaren submitted explanations that cited family obligations and delayed notifications as mitigating factors. Following a series of investigations and suspensions, Alcazaren's employment was terminated on October 15, 1996, due

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Facts:

Employment and Promotion Background

• In 1982, Univet Agricultural Products, Inc. employed Edgardo B. Alcazaren as a casual employee performing sales representative functions in Capiz and Aklan.
• Over time, Alcazaren was promoted to various positions.
• In November 1994, he was promoted to sales supervisor in the West Visayas Area.
• On July 3, 1996, he was transferred, via an inter-office memorandum by Operations Manager Romeo Savella, from West Visayas to East Visayas.
• Alcazaren refused to receive the memorandum notifying him of the transfer.

Disciplinary Directives and Alleged Noncompliance

• On July 10, 1996, Savella ordered Alcazaren to attend a mid-year meeting of sales supervisors in Iloilo City (scheduled for July 15, 1996) and a subsequent meeting in Cebu City on July 16, 1996; Alcazaren failed to attend both.
• On July 16, 1996, Savella directed him to report at the Montebello Hotel, Cebu City, either that day or on July 17, 1996; Alcazaren read the directive but refused to receive it.
• On July 20 and July 27, 1996, Memoranda were issued requiring him to submit written explanations for his failure to attend the meetings and for possible disciplinary sanctions.
• On August 5, 1996, Alcazaren submitted an explanation stating that:
• His grandmother’s death on July 7, 1996 necessitated his attendance at the burial scheduled on July 15, 1996.
• He received notice of the meeting late and attempted to comply by contacting his supervisor, though his arrival at the meeting was delayed, leading to his departure upon being berated.
• The reset of the burial date to July 17, 1996 was also cited as a cause for nonattendance.
• He claimed noncompliance regarding a subsequent memorandum (dated July 20, 1996) was due to delayed receipt.
• On August 12, 1996, Alcazaren was ordered to report to Univet’s Mandaluyong office and to turn over his service vehicle (a 1990 Toyota Corolla, Plate No. PRX-856) along with other company accountabilities; he failed to deliver the vehicle as instructed.
• Between August 14 and September 9, 1996, a series of directives and memoranda were issued by the Personnel Committee regarding:
• Justifying his absences from his area over multiple dates.
• Requiring him to explain his repeated failure to surrender the company vehicle and other accountabilities.
• Establishing that his repeated noncompliance breached the company’s House Rules (e.g., absence without leave for six consecutive days and insubordination/willful disobedience).
• Although Alcazaren eventually turned over the vehicle to a designated representative on September 9, 1996, his persistent defiance in complying with multiple directives raised serious concerns about his conduct.
• Despite being under suspension, on September 3, 1996, he communicated his plan to report to the East Visayas Area but insisted on bringing the vehicle, alleging an option to buy under company policy.

Administrative and Labor Proceedings

• On September 23, 1996, Alcazaren filed a complaint before the NLRC for illegal suspension, constructive dismissal, nonpayment of salaries, and to exercise his alleged option to buy the service vehicle.
• The Labor Arbiter ultimately rendered a decision dismissing the majority of his claims while ordering Univet to pay separation pay and attorney’s fees as a measure of social justice.
• Alcazaren appealed, and the NLRC reversed the Labor Arbiter’s decision by finding that:
• The refusal to turn over the service vehicle did not constitute willful disobedience under the policy that such vehicles are “retirable” only after a year.
• The penalty of dismissal for his attendance issues was excessively harsh considering his 14-year service record.
• He was illegally and constructively dismissed, thus entitling him to reinstatement and backwages.
• Univet elevated the case to the Court of Appeals (CA), arguing that:
• The CA improperly reviewed evidentiary matters from the NLRC and Labor Arbiter decisions, committing grave abuse of discretion.
• The CA erred in its determinations regarding his noncompliance, loss of trust, and the applicability of the service vehicle option-to-buy policy.
• On December 26, 2000, the CA ruled against Alcazaren, holding that:
• He was not constructively dismissed since he was still employed (albeit under suspension) and had not suffered demotion or reduction in pay.
• His defiance of clear management orders (including the shipping of the vehicle to Cebu) amounted to an appropriation of company assets and a breach of trust.
• Under Article 282 of the Labor Code, his termination was justified.
• Alcazaren then filed a petition for review on certiorari before the Supreme Court challenging the CA’s decision and the manner in which it reviewed factual issues and applied relevant laws.

Petitioner’s Arguments in the Supreme Court Petition

• Alcazaren contended that the CA:
• Committed grave abuse of discretion by reviewing evidentiary matters and reexamining facts that should have been left to the NLRC and Labor Arbiter.
• Erroneously held that he was not illegally or constructively dismissed.
• He asserted that his absences were justified and that the disciplinary actions imposed (15-day and 30-day suspensions) were factually and legally baseless, amounting to harassment.
• He maintained that his claim to an option to purchase the service vehicle was valid, arguing that the company's revised motor vehicle replacement policy provided him with ample grounds to retain the vehicle even when directives were issued to surrender it.

Issue:

• Whether Alcazaren’s repeated acts of noncompliance – including refusal to accept transfer orders, failure to attend scheduled meetings, and deliberate non-turnover of the company vehicle – constituted serious misconduct warranting disciplinary measures and ultimately dismissal.
• Whether the disciplinary proceedings, including the imposition of suspensions and the eventual termination of employment, were in accordance with the Company House Rules and the Labor Code (specifically Article 282).
• Whether Alcazaren’s claim of having a legitimate option to buy the service vehicle is legally tenable given the company’s established policy and the timing of his assertion.
• Whether the CA rightly exercised its jurisdiction under Rule 65 of the Rules of Court and under Section 9 of Batas Pambansa Blg. 129 in reviewing and reversing the NLRC and Labor Arbiter decisions regarding factual determinations.
• Whether the dismissal was executed with due process, including proper notice and the opportunity to be heard.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)