G.R. No. 164824 - Aromin vs. National Labor Relations Commission

Case Digest (G.R. No. 164824)
Expanded Legal Reasoning Model

Facts:

Employment and Position

Rolando V. Aromin was an employee of Bank of the Philippine Islands (BPI) for 26 years.
He steadily rose through the ranks to become an Assistant Vice-President (AVP) and at one point headed BPI’s Real Property Management Unit (RPMU).
His long tenure and high rank placed him in a position of trust and confidence, which was vital given his managerial responsibilities.

The Controversial Transaction and Internal Communications

A botched sale involving a trust asset—the Pasig property owned by Philippine Remnants Co., Inc.—became the center of disputes.

In June 1988, BPI, with the concurrence of Philrem, authorized the sale of the property for PhP 1,000 per square meter.
Aromin, as head of RPMU, permitted inspection of the property by Limketkai Sons Milling, Inc. (Limketkai) and a real estate broker.

Key Negotiations and Memoranda

On July 11, 1988, Aromin, together with BPI Vice-President Merlin Albano, engaged in discussions with the Limketkai brothers regarding the payment terms for the property.
Aromin and Albano subsequently prepared a September 6, 1988 memorandum that clarified their stance on Limketkai’s claims, emphasizing that:

Approval of the sale was subject to the concurrence of BPI’s Trust Committee.
There was no assurance that the term payment proposal would automatically be approved.
Limketkai was directed to deal with another vice-president, as they had no further authority regarding the sale.

Subsequent Internal Developments and Performance Issues

Following the filing of a suit for specific performance by Limketkai in Civil Case No. 56316, BPI sought explanations from Aromin and later warned him about alleged inefficiencies such as tardiness, belated submission of work assignments, and unexplained absences.
Aromin was reassigned as Head of the Payroll Section on February 13, 1989.
On February 15, 1989, another memorandum warned Aromin about his unsatisfactory performance.
During the trial of Civil Case No. 56316, Aromin was subpoenaed but failed to appear on November 14, 1990; he eventually testified on December 3, 1990, giving statements that would later turn inconsistent with the memorandum.

Testimony, Inconsistencies, and Resulting Disciplinary Action

Aromin’s December 3, 1990 testimony in court contradicted the earlier joint memorandum by him and Albano:

He claimed that he and Albano were authorized to negotiate the sale, that there existed a “meeting of the minds” indicating a perfected contract of sale, and that the approval by the Trust Committee was a mere formality.
These claims stood in stark contrast to what was stated in the September 6, 1988 memorandum.

As a result of these discrepancies and adverse testimony that harmed BPI’s interests:

On June 10, 1991, the Regional Trial Court rendered a judgment that annulled the BPI-NBS sale.
On June 14, 1991, BPI served Aromin a Notice of Termination, citing willful breach of trust, loss of confidence, and other grounds connected to his conduct.
Aromin then filed a complaint for illegal dismissal, seeking reinstatement, backwages, and other benefits before the National Labor Relations Commission (NLRC).

Proceedings Before the NLRC and Appellate Courts

At the NLRC level:

The Labor Arbiter, on January 3, 1996, found Aromin’s dismissal justified and dismissed his complaint, though he was awarded financial assistance equivalent to one month’s salary for every year of service.
On January 26, 1998, the NLRC reversed part of that decision, awarding full backwages and separation pay, while dismissing other claims.
A subsequent NLRC Resolution on April 29, 1998 reversed the decision awarding financial assistance.

Aromin’s further legal remedies:

Aromin moved for reconsideration before the NLRC, but his motion was denied on February 28, 2003.
He then elevated his case to the Court of Appeals (CA) via a petition for certiorari.

The Court of Appeals, on April 15, 2004, affirmed the NLRC resolutions, sustaining the dismissal of Aromin and denying his petition for relief.
Aromin’s motion for reconsideration was denied by the CA on August 3, 2004.

Issues:

Jurisdiction and Factual Findings

Whether the NLRC and the CA had jurisdiction to substitute their own findings of fact in place of the earlier findings of this Court in the case of Limketkai Sons Milling Inc. vs. Court of Appeals, which found no lawful cause for Aromin’s dismissal.
Whether the substitution of findings amounted to an abuse of judicial discretion.

On the Validity of Dismissal Based on Loss of Trust and Confidence

Whether Aromin’s overall work performance and continued assumption of responsibilities as AVP—even two years after the disputed transaction—negated any lawful basis for his dismissal.
Whether the alleged act of giving false testimony, as well as the inconsistencies between his testimony and the memorandum, justifiably led to a loss of confidence in him.

Due Process in the Dismissal Procedure

Whether Aromin’s termination complied with the due process requirements under the Implementing Rules of the Labor Code, which mandate two written notices and the opportunity to be heard.
Whether the absence of an actual hearing (aside from the opportunity to respond in writing) constituted a denial of due process.

Entitlement to Relief

Whether, as a matter of employment law and given the circumstances of the dismissal, Aromin is entitled to reinstatement, backwages, and/or separation pay.
Whether his long service should be considered a mitigating factor in awarding financial assistance despite the breach of trust.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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Case Digest (G.R. No. 164824) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 164824) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. 164824)
Core Legal Reasoning Model

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Case Digest (G.R. No. 164824)
Expanded Legal Reasoning Model