Case Digest (G.R. No. 223582)
Facts:
Ricardo D. Angeles v. St. Catherine Realty Corporation, et al., G.R. Nos. 223582 and 223788, August 07, 2024, Supreme Court First Division, Marquez, J., writing for the Court.St. Catherine Realty Corporation (St. Catherine) is a subdivision developer that employed Ricardo D. Angeles from March 2001 until June 1, 2010 (as driver, marketing staff, and later surveyor/purchaser) and Francisco Pacheco, Jr. from August 2006 until June 1, 2010 (as landscaper). In March 2010 Angeles and Pacheco were instructed to canvass and procure ornamental plants for the Dizon Estate Subdivision (DES). On March 24, 2010 they purchased plants from Danbel’s Garden (Sales Invoice No. 1134). St. Catherine later discovered that the plants had withered and that the quantities and prices seemed excessive; on May 13, 2010 St. Catherine’s employee purchased similar plants from Danbel’s Garden (Sales Invoice No. 1161), revealing significant price disparities between the two invoices.
St. Catherine investigated, concluded there was misrepresentation/overpricing, and on June 1, 2010 terminated Angeles and Pacheco for "willful breach of the trust reposed in [them]." The corporation also filed criminal estafa charges. Angeles and Pacheco filed a complaint for illegal dismissal before the Labor Arbiter (LA). The LA, in a November 8, 2011 Decision, dismissed their complaint for lack of merit.
On appeal the National Labor Relations Commission (NLRC) reversed on May 28, 2012, finding both illegally dismissed and ordering reinstatement with backwages. The NLRC reasoned that St. Catherine failed to refute Danbel’s owner’s explanation for the price differences and that Angeles and Pacheco did not occupy positions of trust and confidence.
St. Catherine petitioned the Court of Appeals (CA) for certiorari. In a June 8, 2015 Decision the CA granted the petition in part: it held that Pacheco was illegally dismissed but that Angeles was validly terminated for loss of trust and confidence, reasoning that Angeles, as surveyor/purchaser, had control over price information and procurement and failed to satisfactorily explain the invoice discrepancy. The CA denied reconsideration. The Supreme Court consolidated the two Rule 45 petitions (Resolution dated November 16, 2016) and granted review.
Before the Court the parties disputed (among other things) whether the Supr...(Pro-only)
Issues:
- May the Supreme Court review conflicting factual findings of the Labor Arbiter, the NLRC, and the Court of Appeals in a Rule 45 petition?
- Was Ricardo D. Angeles validly dismissed for loss of trust and confidence?
- Was Francisco Pacheco, Jr. validly dismissed for loss of trust and confidence?
- What are the appropriate remedies if...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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