G.R. No. 200352 - Celiz vs. Cord Chemicals, Inc.

Celiz was employed by Cord Chemicals, Inc. since 1992 and rose through the ranks until she became both Chief of Sales and Senior Operations Manager, the second highest ranking position.
The company was privately owned and managed by Leonor Sanz, who inherited management after the demise of her husband, Francisco Sanz, in 2008.
There were personal and professional tensions that surfaced after Francisco’s death. Celiz was allegedly involved in a controversy due to an intimate relationship with Francisco, which allegedly created distrust with Leonor and her family.

After Francisco’s death, Celiz was advised by the new management not to report for work, and later invited to a meeting with Leonor, her children, and two company lawyers at a Makati restaurant.
During the meeting, Celiz was confronted regarding her relationship with Francisco; she maintained the relationship was purely professional and then opted for a graceful exit by tendering her resignation.
Leonor consented to her resignation and indicated that she would be entitled to separation pay, supposedly to be claimed by the end of October 2008.

Shortly after tendering her resignation, Celiz was informed by the company’s counsel that she would be dismissed for failing to account for unliquidated cash advances totaling P713,471.00.
Cord Chemicals, Inc. issued a Notice to Explain, stating that as a managerial employee vested with considerable trust, her failure to liquidate the accounts amounted to dishonest handling of company funds.
Celiz was placed on preventive suspension and told to submit a formal explanation; she requested additional time to review her documents but was only allowed limited access to files and office records during the process.

While Celiz did eventually tender her resignation and claim her separation pay, a routine audit conducted during the clearance process revealed discrepancies in the liquidation of cash advances.
Celiz was given an initial 48-hour period (extended when requested) to explain the charges; however, her explanation was deemed insufficient when compared to the evidence of unliquidated advances.
Subsequent investigation by Leonor uncovered irregularities in Celiz’s handling of sales outputs, including padding figures and failing to address customer complaints, further casting doubt on her integrity.

Celiz filed a complaint for illegal dismissal and monetary benefits before the Labor Arbiter, who ruled that her separation was for just cause after complying with due process, thereby dismissing her claim due to lack of merit.
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, denying Celiz’s claim for reinstatement and other benefits.
Celiz’s petition for review on certiorari was ultimately filed with the Court of Appeals (CA), challenging the decisions of the labor tribunals and asserting that the dismissal was based on fabricated grounds and lacked substantial evidence.

Respondents (Cord Chemicals, Inc., Leonor, and Marian Ontangco) submitted documentary evidence including ledger entries, the Cash Advance Subsidiary Ledger, and Celiz’s own correspondence that indicated her responsibility over the cash advances.
Evidence from company personnel also revealed that Celiz did not comply with standard procedures in liquidating the cash advances, and her behavior during accounting rounds further substantiated claims of negligence and breach of trust.
The records showed that despite being given due process and multiple opportunities to explain herself, Celiz was only partially able to liquidate the advances, leading the company to effect her dismissal for loss of trust and confidence.

Whether the evidence adduced was substantial enough to support the dismissal of Celiz for failing to liquidate significant cash advances.

Did the ledger entries and documentary evidence convincingly associate the unliquidated advances against Celiz’s managerial responsibilities?
Was there clear proof that Celiz benefited from and thus was accountable for the advances?

Whether the procedural due process requirements were met before effecting Celiz’s dismissal.

Was Celiz properly informed of the specific charges against her through the required written notices?
Did the company provide her enough opportunity to review relevant documents and present her explanation?

Whether loss of trust and confidence is an acceptable ground for dismissal even if strict proof beyond reasonable doubt is not required.

How does the doctrine, as interpreted in related cases such as Lima Land, Inc. v. Cuevas, apply to the present case regarding the standard of substantial evidence?
Can the dismissal be justified solely on the basis of managerial discretion in handling cash advances?

Whether the personal allegations regarding Celiz's alleged improper relationship played a role in influencing the dismissal or were used to mask the true administrative issues.

Whether the findings of the Labor Arbiter, NLRC, and the Court of Appeals, all converging on the just cause for dismissal, preclude reexamination of issues of fact in the petition for review.