Case Digest (G.R. No. 119509)
Facts:
Enrique A. Arboleda v. National Labor Relations Commission and Manila Electric Company, G.R. No. 119509, February 11, 1999, Second Division, Bellosillo, J., writing for the Court.Enrique A. Arboleda (petitioner) was a long‑time employee of Manila Electric Company (MERALCO) for 25 years, rising to branch clerk and radio operator at its Novaliches branch. On 18 July 1986, Antonio D. Sy applied for electrical service for his residence and hardware store; during processing Sy was found to have an illegal connection on 6 March 1987 and again on 8 June 1987. Sy testified that on 9 June 1987 he went to the Novaliches MERALCO office and gave about P1,200 to petitioner Arboleda as partial payment for Found Connection (FC) arrears after Arboleda demanded roughly P2,000 for three months’ arrears; Sy said Arboleda accepted the money without issuing an official receipt and later Anonuevo and a man called “Mulong” installed the meter.
Novaliches branch manager Marcelo P. Umali discovered the illegal connection on 16 June 1987, confronted Sy, and learned from Sy and from Sy’s lessor, Sylvia Cruz, that Sy had paid someone at MERALCO. Sy then paid MERALCO officially and his application was granted on 18 June 1987. Umali recommended an investigation of Arboleda. MERALCO notified Arboleda of an investigation (letter dated 21 October 1987) and of his right to representation; Arboleda sought postponement, was suspended on 7 November 1987, and an investigation proceeded on 9 November 1987 where he generally denied knowing Sy, Anonuevo, or Mulong. Arboleda later claimed Anonuevo visited Sy’s house with justificatory papers. Despite suspension he received salary through 11 February 1988, when MERALCO dismissed him under its Company Code of Employee Discipline (Sec. 7, par. 1) for misappropriating or withholding company funds.
Arboleda filed a complaint for illegal dismissal on 20 April 1988. The Labor Arbiter sided with Arboleda, finding (a) Sy’s accusation was prompted by Umali; (b) Sy’s credibility was suspect because of his prior apprehensions for illegal connection; and (c) Sy’s motive was malicious and self‑serving. On MERALCO’s appeal the National Labor Relations Commission (NLRC) reversed the Labor Arbiter on...(Subscriber-Only)
Issues:
- Was petitioner denied due process in MERALCO’s administrative investigation and in the dismissal procedure?
- Was Arboleda’s dismissal supported by a valid cause—serious misconduct (misappropriation/withholding of company funds)?
- Which forum’s factual findings (the Labor Arbiter’s or the NLRC’s) should the Court accept when the two conflict on witness credibility and what standard go...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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