Case Digest (G.R. No. 204750)
Facts:
The case involves Susan D. Capili as the petitioner and the Philippine National Bank (PNB) as the respondent. Capili served as the Assistant Vice President of the Systems and Methods Division at PNB from December 29, 1994, until her dismissal on August 9, 2007. The events leading to her dismissal began on October 8, 2005, when PNB President Omar Byron Mier received allegations from Hyun Duk Cho, a Korean national, claiming that Capili was involved in anomalous transactions. In response, PNB established a Fact Finding Committee, which reported on March 31, 2006, that Capili owned a private company, Sandino Builders (SB), and had engaged in a contract for the sale of scrap metals with Hyun within PNB premises. The report also indicated that Capili had tax liabilities and was listed for violations of Batas Pambansa Blg. 22 (BP 22).
Subsequently, PNB issued a notice to Capili to explain her alleged violations of the bank's Code of Conduct, which included personal work durin...
Case Digest (G.R. No. 204750)
Facts:
Employment Background
- Susan D. Capili (Capili) was employed as the Assistant Vice President - Systems and Methods Division (AVP-SMD) of the Philippine National Bank (PNB) from December 29, 1994, until her dismissal on August 9, 2007.
Allegations of Anomalous Transactions
- On October 8, 2005, PNB President Omar Byron Mier received information from Hyun Duk Cho, a Korean national, alleging that Capili was involved in anomalous transactions.
- PNB formed a Fact-Finding Committee, which reported on March 31, 2006, that Capili owned a private company, Sandino Builders (SB), and had entered into a contract with Hyun for the sale of scrap metals. The signing and payment occurred within PNB premises.
- The Committee also found that Capili had tax liabilities and was involved in Batas Pambansa Blg. 22 (BP 22) cases (bouncing checks).
Administrative Charges
- PNB issued a notice to Capili, requiring her to explain alleged violations of its Code of Conduct, including:
- Doing personal work during office hours.
- Unauthorized use of the bank’s name.
- Commission of a criminal offense involving moral turpitude or breach of trust.
- Capili defended herself, stating that her meetings with Hyun occurred during her personal time, and she disclosed her ownership of SB. She also explained that the BP 22 cases were settled and dismissed.
PNB’s Investigation and Decisions
- PNB’s Investigation, Evaluation, and Charging Division (IECD) charged Capili with:
- Acts showing questionable moral character, integrity, or honesty, constituting loss of confidence.
- Falsification of personnel records.
- On January 16, 2007, PNB’s Administrative Adjudication Panel (AAP) provisionally dismissed the administrative case, pending the resolution of the Bulacan BP 22 case.
- On August 1, 2007, the AAP rendered a second decision, finding Capili guilty of violating PNB’s Policy on Loss of Confidence and dismissed her effective August 9, 2007.
Labor Arbiter and NLRC Rulings
- Capili filed a complaint for illegal dismissal. The Labor Arbiter (LA) ruled in her favor, ordering her reinstatement and payment of backwages.
- The National Labor Relations Commission (NLRC) affirmed the LA’s decision, stating that the BP 22 cases were personal and unrelated to her work.
Court of Appeals Decision
- The Court of Appeals (CA) reversed the NLRC, ruling that Capili’s issuance of worthless checks justified PNB’s loss of trust and confidence.
Issue:
- Whether Capili’s dismissal on the ground of loss of trust and confidence was valid.
- Whether the CA erred in reversing the NLRC’s decision.
- Whether Capili was entitled to reinstatement and payment of salaries and benefits during the appeal period.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court ruled that Capili’s dismissal was illegal. PNB failed to prove that her actions justified loss of trust and confidence, and her reinstatement pending appeal was proper. The CA’s decision was reversed, and the NLRC’s ruling was reinstated.