Facts:

Enrique A. Arboleda, the petitioner, was employed by the Manila Electric Company (MERALCO) for a span of twenty-five years, starting from 1963 until his dismissal on February 11, 1988. He climbed the ranks to hold positions such as branch clerk and later radio operator at MERALCO’s Novaliches branch. The events that led to his dismissal began on July 18, 1986, when Antonio D. Sy applied for electrical service at a property he leased from Renato and Sylvia Cruz. During the processing of his application, Sy was found to have made illegal electrical connections on two separate occasions—March 6 and June 8, 1987.

On June 9, 1987, when Sy attempted to settle his Found Connection (FC) bills amounting to approximately P2,000.00, he encountered Arboleda, who accepted a partial payment of P1,200.00 without issuing an official receipt. Subsequently, Arboleda arranged for the installation of the meter through Brigido "Adu" Anonuevo and another individual. This incident was broug

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Facts:

Employment Background

• Enrique A. Arboleda served MERALCO for 25 years, beginning in 1963 and ending on 11 February 1988.
• He advanced in his career from being a branch clerk to serving as the radio operator of MERALCO’s Novaliches branch.

Incident Leading to Disciplinary Action

• On 18 July 1986, Antonio D. Sy applied for electrical service for his residence and his hardware store located on leased premises.
• Sy was later discovered to have an illegal electrical connection—first on 6 March 1987 and again on 8 June 1987.
• On 9 June 1987, Sy visited the MERALCO office in Novaliches to settle his Found Connection (FC) bills and met Arboleda.
• Arboleda informed Sy that he needed to pay approximately P2,000.00 for three months of FC bills before installation of a meter could proceed.
• Sy, however, only had P1,200.00 and handed that amount over to Arboleda, who accepted the money without issuing an official receipt.
• Following this transaction, Arboleda sent Brigido "Adu" Anonuevo and a person known only as “Mulong” to install the meter.

Discovery and Internal Investigation

• On 16 June 1987, Marcelo P. Umali, the branch manager of MERALCO at Novaliches, observed the illegal connection at Sy’s premises and confronted Sy about it.
• Upon questioning, Sy maintained that he had paid his FC bills to Arboleda, a claim corroborated by Sylvia Cruz.
• Acting on the information, Umali recommended that Arboleda be investigated, and on 18 June 1987, he submitted his recommendation to his supervisor, R. A. Villanueva.
• On 21 October 1987, MERALCO’s Atty. Anecito A. Mejorada formally notified Arboleda of the impending investigation scheduled for 27 October 1987.
• Arboleda requested a postponement of the investigation; however, the matter proceeded and on 7 November 1987, he was suspended pending the investigation.
• During the investigation on 9 November 1987, Arboleda gave a general denial regarding his association with Sy, “Adu”, and “Mulong.”
• Arboleda later submitted documents including an Affidavit of Justification and a Certificate of Attendance at a MERALCO seminar, along with Sy’s Affidavit of Desistance, as part of his defense.

Dismissal and Post-Investigation Events

• Despite being under suspension, Arboleda continued to receive his salary from 20 December 1987 until his dismissal on 11 February 1988.
• His dismissal was effected for alleged misappropriation of company funds, in line with Section 7, paragraph 1, of MERALCO’s Company Code of Employee Discipline.
• On 20 April 1988, Arboleda filed a case against MERALCO alleging illegal dismissal.
• The Labor Arbiter sustained his complaint on three primary grounds:
• Sy’s charges were allegedly prompted by Umali.
• Sy’s credibility was questioned due to his history of illegal electrical connections.
• Sy’s testimony was viewed as motivated by self-preservation rather than truth.

NLRC Review and Findings

• On appeal by MERALCO, the NLRC reversed the favorable decision of the Labor Arbiter.
• The NLRC found that:
• There was no proof of instigation on the part of Umali in prompting Sy’s accusation.
• Sy’s testimony was categorical, spontaneous, and replete with consistent details, thus credible.
• The exculpatory evidence presented by Anonuevo was undermined and characterized as a ruse.
• Based on the findings, NLRC determined that Arboleda was guilty of serious misconduct warranting his dismissal.

Procedural Due Process Considerations

• Arboleda contended that he was denied due process, particularly the opportunity to confront witnesses against him during the investigation.
• The evidentiary record revealed that:
• MERALCO had provided a written notice outlining the impending investigation and the charges against him (dated 21 October 1987).
• MERALCO subsequently issued a written notice of dismissal on 11 February 1988, clearly stating the reasons for termination.
• The Court noted that in administrative proceedings, the essence of due process is the chance to explain one’s side, which in this case was deemed substantially satisfied.

Issue:

Due Process

• Was Arboleda afforded his constitutional right to due process during the MERALCO investigation and disciplinary proceedings, especially his right to confront adverse witnesses?
• Did MERALCO’s method of conducting the investigation and imparting notice satisfy the minimal procedural requirements?

Validity of Dismissal

• Was the dismissal of Arboleda for misappropriation of funds legally justified?
• Did the evidence, particularly the testimonial accounts of Antonio Sy and the conflicting evidence of Anonuevo, establish a valid cause for dismissal under Article 282 of the Labor Code?

Credibility and Weight of Evidence

• How should the conflicting testimonies—Sy’s affirmative and detailed account versus Anonuevo’s negative and inconsistent assertions—be weighed?
• Does the evidence support the NLRC’s finding that Sy’s testimony was credible and free of ulterior motive?

Deference to Administrative Findings

• Should this Court give deference to the factual findings of the NLRC over those of the Labor Arbiter, especially when there are issues concerning witness credibility?
• To what extent can administrative findings be reexamined when a tangible conflict arises in the record?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)