Facts:

The case involves the Baguio Country Club Corporation (petitioner) and Jimmy Sajonas (respondent). On August 18, 1978, the petitioner filed an application with the Ministry of Labor in Baguio City seeking clearance to terminate Sajonas' employment, citing multiple allegations including willful breach of trust, dishonesty, and violations of club rules. Sajonas opposed the termination, claiming it was unjustified and violated his constitutional right to security of tenure. Following a notice of investigation, the case was referred to a conciliator who recommended Sajonas' preventive suspension. The Regional Director subsequently suspended him and forwarded the case to Labor Arbiter Benigno Ayson. On December 11, 1978, the labor arbiter ruled against the petitioner, denying the application for clearance to dismiss Sajonas due to insufficient evidence. The arbiter ordered Sajonas' reinstatement with back wages and without loss of seniority rights. The petitioner appea...

Facts:

Background of the Case

• The petitioner, Baguio Country Club Corporation, filed an application with the Ministry of Labor in Baguio City on August 18, 1978, seeking clearance to terminate the employment of respondent Jimmy Sajonas for multiple alleged infractions including willful breach of trust, dishonesty, and violations of club rules.
• Jimmy Sajonas, the employee, opposed the dismissal, asserting that his termination lacked justifiable grounds and violated his constitutional right to security of tenure.

Pre-Arbitration Proceedings and Evidence Submission

• The case underwent conciliation where the Ministry of Labor issued a notice of investigation for September 7 and September 15, 1978.
• The petitioner submitted a detailed position paper accompanied by the application for termination and copies of sworn statements from witnesses detailing the alleged infractions, including an incident on August 6, 1978, involving misappropriation of funds and misuse of a chit for covering up a transaction.
• Jimmy Sajonas, on the other hand, filed a minimal opposition comprising a brief two-paragraph statement, and he did not submit his own detailed position paper.

Arbitration and Irregularities in Procedure

• As the case was referred for compulsory arbitration to Labor Arbiter Benigno Ayson, irregularities emerged:
• Respondent Sajonas failed to appear personally at the arbitration proceedings, instead, his union members spoke on his behalf.
• A last-minute position paper was allowed to be filed by Sajonas without serving a copy on the petitioner, depriving the petitioner the opportunity to refute or rebut its contents.
• The labor arbiter subsequently rendered a decision on December 11, 1978, denying the petitioner’s application for clearance, concluding there was an insufficiency of evidence to support termination.

Administrative and Appellate Process

• The petitioner challenged the decision by the labor arbiter, arguing that its evidence was neither duly considered nor properly confronted, thus denying due process.
• On January 17, 1980, the National Labor Relations Commission (NLRC) affirmed the labor arbiter’s decision.
• The petitioner charged the public respondents with grave abuse of discretion, contending that the summary procedures used were irregular, one-sided, and contrary to the factual records and applicable law.

Establishment of Key Facts Through Documentary Records

• Testimonies and evidentiary records highlighted the following:
• On August 6, 1978, Miss Bernadette Saliquio testified that bartender Jimmy Sajonas pocketed a cash payment of P7.00 and misused company chit documents during a transaction.
• Miss Alma Jean Quidasol corroborated the incident and reported that Sajonas threatened her for disclosing the anomaly.
• Miss Cristina Rico verified the threat by Sajonas, using the term “papatayin.”
• Subsequent criminal actions, including an information for estafa and a complaint for grave threats, further underscored the allegations against Sajonas, though the threat case was dismissed for prescription.

Issue:

Denial of Due Process

• Whether the petitioner’s evidence, submitted during the conciliation stage, was improperly disregarded by the labor arbiter and the NLRC, thereby denying the petitioner its right to due process.
• Whether the irregular procedural conduct—particularly, the acceptance of a late position paper from the respondent without serving a copy to the petitioner—resulted in a one-sided and unfair decision.

Sufficiency and Timing of Evidence

• Whether the evidence admitted at the labor arbitration was inadequate to justify the dismissal of Sajonas, given that the petitioner’s detailed position paper and accompanying sworn statements were not properly considered.
• Whether the submission of critical evidence solely on appeal, rather than during the initial conciliation, affected the integrity of the administrative proceeding.

Abuse of Discretion

• Whether the decision to affirm the labor arbiter’s ruling—despite clear procedural irregularities and the blatant disregard of substantial evidence—amounted to a grave abuse of discretion by the NLRC.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)