G.R. No. 208163 - Benitez vs. Santa Fe Moving and Relocation Services/Vedit Kurangil

Petitioners Roque B. Benitez and Santa Fe Labor Union filed a complaint for unfair labor practice, illegal dismissal, and money claims against Santa Fe Moving and Relocation Services and its Managing Director, Vedit Kurangil.
Benitez had been employed as a packing and moving operator (crew leader) since June 2001 and also served as the union’s Vice-President.
The case arose from an incident during the company’s Christmas Party on December 18, 2010.

Benitez denied verbally abusing his superior, claiming that his actions were directed against irregularities in the conduct of the raffle during the party.
He contended that his dismissal was an unfair labor practice motivated by the company's desire to derail a collective bargaining agreement.
Benitez maintained that the penalty of dismissal was disproportionate given that the incident occurred during a casual gathering and was unrelated to his work.

The company asserted that during the Christmas Party, Benitez became unruly by climbing the stage and vehemently questioning the raffle process, which allegedly affected the chances of contractual employees in winning prizes.
Evidence presented indicated that Benitez verbally abused the managing director, using expletives such as “putang ina mo ka VK, gago ka!” in the presence of employees, their families, and company guests.
Witnesses including company employees and guests, through affidavits and depositions, corroborated the occurrence of the outburst and its disruptive nature, contradicting testimonies of other employees who claimed he remained calm.

Following the incident, the company required Benitez to provide a written explanation regarding his conduct; his failure to comply led to a memorandum dated December 20, 2010 terminating his employment on grounds of serious misconduct or willful disobedience as defined under Article 282 of the Labor Code.
The Labor Arbiter dismissed the complaint for lack of merit, holding that Benitez committed a serious misconduct by verbally abusing his superior.
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision though noting non-compliance with the two-notice requirement in the dismissal, and awarded Benitez nominal damages of ₱50,000.00 for the procedural lapse.
The Court of Appeals (CA) later upheld the NLRC’s ruling, echoing that the evidence sufficiently supported the dismissal for serious misconduct but modified the award of nominal damages.

That Benitez did not commit serious misconduct since his conduct was not directly related to his work and the incident occurred in an informal setting.
They asserted that the CA misapplied established jurisprudence, particularly distinguishing the present case from the facts of Samson v. NLRC where misconduct was evaluated differently.
They argued that protective measures, such as intervention by company guards, were absent, which should have negated or mitigated his liability.

That Benitez’s actions on stage, including the public verbal abuse against his superior and nearly physical altercation, clearly constituted serious misconduct.
That the incident’s occurrence in front of a large audience – comprising employees, their families, and guests – significantly harmed the company’s reputation and discipline.
That although procedural lapses (failure of two-notice) existed, the gravity of the misconduct justified his dismissal and warranted the reduction, not annulment, of nominal damages.

Whether the facts of the case established that Benitez committed serious misconduct under Article 282 of the Labor Code.

Was the nature and context of his unruly behavior at the Christmas Party sufficient to warrant dismissal?
Did his public verbal abuse against his superior and other company officials meet the threshold for serious misconduct?

Whether the petitioners’ arguments, including those based on Samson v. NLRC, successfully distinguish the present case from other instances of employee misconduct.

Can the informal context of a Christmas gathering and alleged procedural deficiencies (e.g., failure to observe the two-notice requirement) mitigate the gravity of his actions?

Whether the questions raised by petitioners pertain to issues of fact or issues of law, particularly in the interpretation of “serious misconduct” and its application to the incident.

Does the evaluation involve determination of the probative value of the evidence (a factual issue) or the legal standard for serious misconduct (a question of law)?

Whether the award for nominal damages should be modified in view of the procedural lapses identified in the dismissal process.