Facts:

The case involves AMA Computer College-East Rizal (AMACC-ER), Amable C. Aguiluz, and Anthony Jesus R. Vince Cruz as petitioners, and Allan Raymond R. Ignacio as the respondent. The events leading to the case began on September 25, 1998, when Ignacio was first employed at AMA Computer College-Fairview (AMACC-FV) as a Management Trainee with a monthly salary of P7,700.00. He was granted permanent status three months later, with a salary increase to P11,000.00. On August 16, 1999, he was transferred to AMACC-ER due to an impending ISO 9000 certification inspection scheduled for the first week of September 1999.

On his first day at AMACC-ER, Ignacio consulted with various officials regarding a renovation plan for the school facilities, which was part of the ISO 9000 compliance. He began demolishing a concrete partition wall in the computer laboratory on August 18, 1999, without proper authorization from the IT Department, which led to the exposure of 35 computer units to poten...

Facts:

Parties Involved and Employment Background

• Petitioner AMA Computer College, Inc. (AMACCI) is a corporation providing computer education with several branches, including AMA Computer College-East Rizal (AMACC-ER).
• Petitioner officials include Amable C. Aguiluz (President) and Anthony Jesus R. Vince Cruz (Human Resource Director).
• Respondent Allan Raymond R. Ignacio was employed as a Management Trainee (later confirmed as Maintenance Supervisor) initially at AMA Computer College-Fairview (AMACC-FV) and later transferred to AMACC-ER.

Employment History and Transfer Details

• Respondent’s initial employment started on 25 September 1998 with subsequent confirmation and salary increase on 29 December 1998.
• Based on the recommendation of the AMACC-ER School Director/Chief Operating Officer, Lydia Taganguin, and following a pressing deadline for ISO 9000 certification, respondent was transferred to AMACC-ER effective 16 August 1999.
• The transfer was connected to ensuring smooth operations during the ISO 9000 inspection of the school facilities.

Renovation Plan and Initial Actions

• On his first day at AMACC-ER, respondent consulted with several officials regarding the renovation plans for the school premises, particularly the computer laboratory within the JL Domingo Building.
• He secured the renovation plan which had been approved by higher management (including AMA Educational System’s Vice-President Zenaida Carpio), through the intervention of the AMACC-ER School Director.
• Acting on this plan, respondent initiated the demolition of the concrete partition wall in the computer laboratory on 18 August 1999.
• The following day, maintenance personnel were ordered to bring plywood to cover the unfinished door opening; however, the demolition and subsequent actions were executed without informing all concerned departments.

Discovery of Alleged Negligence and Subsequent Investigation

• On 25 August 1999, an internal audit complaint was filed against respondent alleging “threatening to damage company property, negligence or failure to exercise adequate asset control measures.”
• A memorandum dated 2 September 1999, issued by Human Resource Director Cruz, charged respondent with inexcusable gross negligence resulting in damage to 35 computers and loss of class records/exams and directed him to submit his written explanation.
• Respondent was placed on preventive suspension and called to an emergency meeting on 3 September 1999 where he was given the opportunity to explain his actions.
• Testimonies of various committee members and employees during the meeting revealed that respondent had started demolition without obtaining written approval or proper coordination with the IT and other related departments.

Disciplinary Proceedings and Administrative Decisions

• Based on the findings of the investigation, the Human Resource Department recommended dismissal for respondent, citing violation of the company code of conduct (Rule E Section 4).
• Consequently, respondent was terminated from employment on 9 September 1999.
• Respondent filed a complaint with the National Labor Relations Commission (NLRC) on 27 October 1999 for illegal dismissal and other claims relating to unpaid wages and benefits.
• The Labor Arbiter and subsequently the NLRC affirmed that the dismissal was legal, finding that respondent committed a serious offense by unauthorized demolition, exposing computer equipment and causing the loss of class records.

Appellate Proceedings and Certiorari

• Dissatisfied with the NLRC’s results, respondent filed an appeal which led to a Petition for Certiorari (CA-G.R. SP No. 67047) before the Court of Appeals.
• In its Decision dated 22 December 2006, the Court of Appeals reversed the NLRC ruling, holding that respondent was illegally dismissed.
• The CA found that although respondent was negligent, his actions did not amount to gross or habitual misconduct warranting dismissal, noting that there was no willful intention to cause damage.
• Petitioners’ Motion for Reconsideration was later denied via a Resolution dated 4 June 2007.
• The petitioners further raised issues before the Supreme Court challenging the re-evaluation of factual findings and questioning both procedural and substantial aspects of the dismissal.

Issue:

Jurisdiction and Factual Re-Evaluation

• Whether the Court of Appeals exceeded its jurisdiction by independently re-assessing the findings of fact originally made by the Labor Arbiter and the NLRC.
• Whether the appellate court’s action in making its own factual determinations was permissible under recognized exceptions from the general rule of deference to administrative findings.

Admissibility and Weight of Evidence

• Whether the Court of Appeals erred in dismissing evidence submitted by petitioners on the ground that it was not rendered under oath, despite such evidence being substantial in challenging the allegations of gross negligence.

Qualification of Misconduct and Just Cause for Dismissal

• Whether respondent’s act of demolishing the partition wall without further coordination constituted serious misconduct warranting dismissal.
• Whether the negligence exhibited, including failure to secure equipment and safeguard class records, was of such gravity to merit termination, given that similar instances were otherwise subject to lesser sanctions.

Procedural Due Process

• Whether respondent was provided with sufficient notice and opportunity to be heard, thus meeting the minimum due process requirements in termination procedures.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)