Case Digest (G.R. No. 123646)
Facts:
Nazario C. Austria v. National Labor Relations Commission, Abeto A. Uy and Philippine Steel Coating Corporation, G.R. No. 123646, July 14, 1999, the Supreme Court Second Division, Bellosillo, J., writing for the Court. Petitioner Nazario C. Austria was hired by private respondent Philippine Steel Coating Corporation (PHILSTEEL) on 19 December 1985 as Credit and Collection Manager and, on 11 August 1987, executed a Confidentiality Agreement not to disclose company technical or operational information.Tensions arose after a 13 July 1989 telefax from one Felix Lukban to PHILSTEEL’s Australian supplier, Bliss Fox Manufacturing Corporation (BLISS FOX), inquiring about machinery for a galvanizing plant. On 5 August 1989 a BLISS FOX representative, Charles Villa, allegedly informed PHILSTEEL’s president Abeto Uy of the fax and, after a telephone inquiry, indicated that Lukban said his contact at PHILSTEEL was “Rudy” (petitioner). PHILSTEEL investigated, questioned Austria about his relationship with Lukban and alleged plans to form a rival galvanizing business, and on 17 August 1989 terminated Austria, taking his room and company car keys and padlocking his room and barricading the car. Austria denied sending the fax; Lukban executed an affidavit (13 December 1989) and testified denying Austria’s involvement. PHILSTEEL presented testimony by company officers and the confidentiality agreement as support for dismissal.
Austria filed for illegal dismissal on 30 August 1989. The Labor Arbiter found PHILSTEEL’s evidence credible, held the dismissal legal but awarded P24,000 as separation pay (finding no proof of loss or of an existing rival company). On appeal the National Labor Relations Commission (NLRC) sustained the finding of just cause but modified the award to P1,000 indemnity for partial denial of due process (no prior written notice...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion in upholding petitioner’s dismissal for alleged loss of trust where the employer’s evidence was largely hearsay and speculative?
- Did the partial denial of due process warrant relief beyond the indemnity awarded by the NLRC, and what is th...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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