Facts:

The case involves Brown Madonna Press, Inc. (BMPI), Thaddeus Anthony A. Cabangon, Fortune Life Insurance Company (now Fortune General Insurance Corporation), and/or Antonio Cabangon Chua as petitioners, and Maria Rosario M. Casas as the respondent. The events leading to the dispute began on January 5, 2007, when Casas, who was the Vice President for Finance and Administration at BMPI, met with Cabangon and Victoria Nava, the Vice President for the Central Human Resource Department of the ALC Group of Companies. During this meeting, Casas claims she was forced to leave her position, while BMPI contends that she requested a graceful exit to avoid an impending administrative investigation regarding complaints against her.

Casas had been employed since May 1, 1984, starting as an accounting clerk at Fortune General Insurance and eventually being transferred to BMPI on December 1, 2003. Following the January 5 meeting, she was instructed not to report to work starting January 8...

Facts:

Employment History and Position:

• Maria Rosario M. Casas (Casas) was hired as an accounting clerk at Fortune General Insurance on May 1, 1984, and later transferred to Brown Madonna Press, Inc. (BMPI) on December 1, 2003, as Vice President for Finance and Administration.

Termination of Employment:

• On January 5, 2007, Casas met with BMPI President Thaddeus Anthony Cabangon and Victoria Nava, Vice President for the Central Human Resource Department of the ALC Group of Companies. Casas claims she was told not to report to work starting January 8, 2007, upon the instructions of Antonio Cabangon Chua, ALC's Chairman Emeritus. She was promised separation pay but was not given a reason for her dismissal.
• BMPI, however, asserts that Casas voluntarily requested a "graceful exit" to avoid an administrative investigation into alleged irregularities and a growing rift with another company officer. BMPI claims Casas convinced Cabangon to grant her financial assistance due to their friendship.

Post-Termination Events:

• Casas did not report to work on January 8, 2007, and BMPI began processing her clearance.
• On May 17, 2007, Casas sent a letter to Cabangon-Chua seeking reconsideration of her termination, but no action was taken.
• On July 20, 2007, Casas filed a complaint for illegal dismissal, seeking separation pay, backwages, retirement benefits, and attorney’s fees before the Regional Arbitration Branch.

Labor Arbiter’s Ruling:

• The Labor Arbiter (LA) dismissed Casas’ complaint, finding that she had abandoned her post rather than being dismissed. The LA noted the absence of a written notice of dismissal and concluded that Casas left to preempt an investigation. The LA ordered her reinstatement without backwages to allow BMPI to conduct a proper investigation.

NLRC’s Ruling:

• The National Labor Relations Commission (NLRC) reversed the LA’s decision, finding that Casas had been illegally dismissed. The NLRC cited the "Clearance and Quitclaim" document issued by BMPI, which stated that Casas would cease to be connected with the company as of January 16, 2007, as evidence of her termination. The NLRC also found that BMPI failed to comply with procedural due process requirements, such as providing Casas with notice and an opportunity to defend herself.

Court of Appeals’ Decision:

• The Court of Appeals (CA) affirmed the NLRC’s ruling, holding that Casas was illegally dismissed. The CA emphasized that BMPI failed to provide the required two-notice procedure for termination and that the allegations against Casas were unsubstantiated at the time of her dismissal.

Issue:

The sole issue before the Supreme Court was whether the Court of Appeals erred in finding that the NLRC did not commit grave abuse of discretion in ruling that Casas had been illegally dismissed.

Ruling:

The Supreme Court dismissed the petition and affirmed the CA’s decision. The Court held that:

1. Casas was illegally dismissed: The NLRC and CA correctly found that Casas was dismissed without just cause and without due process. BMPI failed to provide the required two-notice procedure and did not substantiate the allegations against Casas at the time of her dismissal.

2. Burden of Proof: The burden of proving just cause for dismissal lies with the employer. BMPI failed to meet this burden, as the allegations against Casas were unproven and speculative at the time of her termination.

3. Procedural Due Process: BMPI violated Casas’ procedural due process rights by failing to provide her with the required notices and an opportunity to defend herself.

4. Substantive Due Process: Casas’ dismissal lacked substantive justification, as the alleged infractions were not proven with substantial evidence at the time of her termination.

Ratio:

1. Illegal Dismissal: An employee’s dismissal is illegal if it is not based on just or authorized causes and does not comply with procedural due process requirements. In this case, BMPI failed to establish just cause for Casas’ dismissal and did not follow the required procedural steps.

2. Burden of Proof: The employer bears the burden of proving that the dismissal was for a valid cause and that due process was observed. BMPI failed to meet this burden, as the allegations against Casas were unsubstantiated at the time of her termination.

3. Procedural Due Process: The Labor Code requires employers to provide employees with two written notices before termination: (1) a notice specifying the grounds for termination and (2) a notice of the decision to terminate after giving the employee an opportunity to respond. BMPI failed to comply with these requirements.

4. Substantive Due Process: Just cause for dismissal must be supported by substantial evidence at the time of termination. Mere accusations or unproven allegations are insufficient to justify dismissal.

5. Presumption of Innocence: An employee is presumed innocent until proven guilty of alleged infractions. BMPI’s failure to investigate and substantiate the allegations against Casas rendered her dismissal invalid.

Conclusion:

The Supreme Court affirmed the CA’s decision, ruling that Casas was illegally dismissed. BMPI failed to prove just cause for her termination and violated her procedural and substantive due process rights. The petition was dismissed, and the CA’s decision was upheld.