G.R. No. 97817 - Aris Philippines, Inc. vs. National Labor Relations Commission

Parties and case background
Petitioner: Aris Philippines, Inc. (employer).
Private respondents: National Labor Relations Commission (NLRC), Confederation of Filipino Workers-Aris Philippines Workers Union (Union), and employee Arnel Santos (complainant/respondent below).

Incident and immediate aftermath
On 28 September 1988, an altercation occurred in the company canteen between employee Arnel Santos and canteen helper Eufemia Bautista after Bautista questioned Santos for using somebody else’s identification card. Santos reacted by shouting invectives (“wala kang pakialam! Kung gusto mo, itapon ko itong mga pagkain ninyo”), left the canteen, returned minutes later to challenge by saying “Sino ba ang nagagalit?”, smashed food items on display, and slapped Bautista, causing her to fall and suffer slight contusions.
The security officer-in-charge submitted a report to company officials. Bautista filed a written complaint with Jesus Perez, personnel manager of Aris Philippines. Perez issued a memorandum and required Santos to submit a written explanation.

Administrative and criminal proceedings
Santos submitted a written explanation (the record indicates he admitted misconduct and explained he was under the influence of liquor at the time). A letter dated 17 October 1988 terminated Santos’ employment for “gross misconduct seriously violative of (the) company rules and regulations.”
Bautista filed a barangay (Lupong Tagapayapa) complaint and then a complaint for slight physical injuries with the Municipal Trial Court of Pasig; she later executed an affidavit of desistance and the criminal complaint was dismissed.

Labor proceedings and decisions below
Santos and the Union filed a complaint for illegal dismissal before the Labor Arbiter. On 21 July 1989, Labor Arbiter Edilberto J. Pangan ordered Santos reinstated to his former or equivalent position without backwages, holding that the dismissal penalty was too severe (the period from dismissal until reinstatement to be considered the penalty).
Aris Philippines appealed to the NLRC. On 28 December 1990, the NLRC affirmed the Labor Arbiter’s decision, observing that the slapping/punching incident occurred in the canteen, was not connected with Santos’ employment, did not disrupt company operations, and therefore dismissal was excessive.
Aris’ motion for reconsideration was denied by NLRC resolution dated 14 February 1991.

Supreme Court action
Petitioner Aris Philippines filed a petition for certiorari (G.R. No. 97817) assailing the NLRC decision and the NLRC resolution denying reconsideration, arguing NLRC gravely abused its discretion in holding the acts did not constitute serious misconduct warranting dismissal.
The Supreme Court issued a temporary restraining order on 15 April 1991 (later lifted).
The Supreme Court rendered judgment on 10 November 1994, dismissing the petition and affirming the findings below. The opinion was penned by Justice Vitug; Justices Bidin, Romero, and Melo concurred; then-Chairman Feliciano was on leave.

Procedural and factual issues
Whether the NLRC gravely abused its discretion in finding the misconduct of employee Santos was not a just cause for dismissal.

Substantive legal issues
Whether the acts committed by Santos constitute “serious misconduct” or other just causes for termination under Article 282 of the Labor Code.
Whether misconduct committed by an employee in a non-work situation (canteen altercation) can be a valid ground for dismissal if it is not connected with the employee’s duties or does not disrupt company operations.