Title
Central Azucarera De Bais vs. Heirs of Apostol
Case
G.R. No. 215314
Decision Date
Mar 14, 2018
Employee dismissed for unauthorized use of company equipment for personal repairs; Supreme Court upheld termination, citing breach of trust and due process compliance.
Font Size:

Case Digest (G.R. No. 215314)

Facts:

Employment Background

  • Zuelo Apostol (respondent) was employed by Central Azucarera de Bais (CAB) for 20 years, starting on March 1, 1982, as the Motor Pool Over-All Repairs Supervisor. His responsibilities included assigning personnel and equipment for repair jobs and taking custody of CAB's repair equipment and materials. He was also provided a company house as part of his employment benefits.

Incident Leading to Termination

  • On February 2, 2002, a security guard, Tomasito Rosel, reported that Apostol was using his company house and CAB equipment to repair privately owned vehicles. Specifically, Rosel observed Apostol using company materials, such as steel plates and an oxygen-acetylene outfit, to repair a Lancer car and a pick-up vehicle.

Company Action

  • CAB issued a memorandum to Apostol on February 4, 2002, accusing him of violating Rule 9 of CAB's Rules of Discipline, which prohibits the use of company materials or equipment for private work without permission. Apostol was placed on preventive suspension and asked to submit a written explanation within 24 hours.

Apostol's Response

  • Apostol admitted to the violation in a handwritten explanation, apologizing for repairing his personal vehicle without permission. He claimed he only used a trouble light and his personal acetylene and oxygen, not company equipment.

Termination

  • On February 8, 2002, CAB terminated Apostol's employment, citing his violation of company rules. Apostol vacated the company house and filed a complaint for constructive dismissal, illegal suspension, and other labor claims before the Sub-Regional Arbitration Branch No. VII of Dumaguete City.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Management Prerogative: Employers have the right to exercise management prerogatives, including the dismissal of employees for just cause, provided procedural and substantive due process are observed.
  2. Procedural Due Process: The "ample opportunity to be heard" standard does not require a formal hearing unless requested by the employee or necessitated by substantial evidentiary disputes. CAB's issuance of two notices satisfied this requirement.
  3. Substantive Due Process: Apostol's violation of company rules, particularly the unauthorized use of company property for personal gain, constituted a breach of trust and confidence. As a supervisor, his actions warranted dismissal.
  4. Penalty Proportionality: The penalty of dismissal was proportionate to the offense, given Apostol's position of responsibility and the impact of his actions on the company.
  5. No Entitlement to Backwages and Separation Pay: Since the dismissal was valid, Apostol was not entitled to backwages or separation pay.

Conclusion:

The Supreme Court reinstated the Labor Arbiter's decision, upholding CAB's dismissal of Apostol. The Court emphasized the importance of respecting an employer's management prerogative while ensuring compliance with due process requirements.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.