Title
Arandilla, Jr. vs. Maguindanao Electric Cooperative, Inc.
Case
G.R. No. 157329
Decision Date
Jul 28, 2005
A MAGELCO General Manager, accused of misconduct, was suspended and later dismissed. NLRC ruled illegal dismissal, ordering separation pay over reinstatement due to lost trust. Courts upheld NLRC's authority to modify its decision.
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Case Digest (G.R. No. 157329)

Facts:

Employment and Promotion:

  • Genaro O. Arandilla, Jr. (petitioner) was employed by Maguindanao Electric Cooperative, Inc. (MAGELCO) in March 1977 as a construction worker groundman. He was later promoted to General Manager with a monthly salary of P34,451.00.

Allegations and Investigation:

  • In March 1990, MAGELCO received complaints against petitioner, including allegations of accepting P10,000.00 from Paraoan Rice Mill, unauthorized disposal of used transformer oil, payment for undelivered poles, and non-compliance with purchasing procedures.
  • An Ad Hoc Committee investigated the matter and recommended a 45-day suspension. The recommendation was endorsed to the National Electrification Administration (NEA).

NEA's Actions:

  • NEA's Administrative Committee initially recommended petitioner's removal as General Manager. However, the NEA Board of Directors, considering petitioner's 22 years of service, issued Resolution No. 36 on May 21, 1996, suspending him for three months.
  • MAGELCO's Board of Directors refused to comply with NEA's resolution, arguing that NEA lacked authority to suspend the General Manager.

Further Developments:

  • NEA conducted a financial audit of MAGELCO, confirming that petitioner's actions were prejudicial to the cooperative. Petitioner was asked to submit a written explanation but failed to do so.
  • On July 30, 1999, MAGELCO's Board of Directors issued Resolution No. 66(a), terminating petitioner's services.

Labor Case:

  • Petitioner filed a complaint for illegal dismissal, wages, damages, and attorney's fees with the Regional Arbitration Branch No. XII (RAB Case No. 12-08-00082-99).
  • The Labor Arbiter dismissed the complaint, finding no illegal dismissal. On appeal, the National Labor Relations Commission (NLRC) reversed the decision, ruling that petitioner was illegally dismissed and ordering his reinstatement or payment of separation pay.

NLRC's Subsequent Resolutions:

  • The NLRC initially ordered reinstatement but later modified its decision, directing payment of separation pay instead, citing the impracticality of reinstatement due to loss of trust and confidence.

Court of Appeals Decision:

  • The Court of Appeals affirmed the NLRC's modified decision, holding that the NLRC's initial resolution was not yet final and could be modified.

Issue:

  1. Whether the NLRC could modify its October 31, 2000 Resolution, which had already become final and executory.
  2. Whether the NLRC committed grave abuse of discretion in ordering payment of separation pay instead of reinstatement.

Ruling:

The Supreme Court denied the petition, affirming the Court of Appeals' decision. The NLRC's October 31, 2000 Resolution was not yet final as to the petitioner, who had filed a motion for reconsideration. Therefore, the NLRC did not commit grave abuse of discretion in modifying its decision to order payment of separation pay instead of reinstatement.

Ratio:

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