G.R. No. 208738-39 - Citigroup Business Process Solutions Pte. Ltd. vs. Raymundo B. Corpuz

Petitioner Citigroup Business Process Solutions Pte. Ltd. (Citigroup) employed respondent Raymundo B. Corpuz (Corpuz) as a Customer Solutions Officer on October 20, 2006.
At hiring, Corpuz signed an employment contract, a Privacy Promise Agreement, and a Patent and Confidential Information Agreement, aimed at securing confidentiality of customer and company information.

On July 3, 2007, Corpuz received a call from an individual claiming to be an officer of Metlife, an insurance provider affiliated with Citigroup.
The caller inquired about an unclaimed check payable to a Citigroup account holder. Corpuz disclosed the customer’s name, address, account number, home phone, and mobile number.
Corpuz also stated that the mortgage account had been discharged and possibly refinanced or sold.

Corpuz’s supervisor reprimanded him for revealing confidential information to an unknown third party on July 4, 2007.
Citigroup issued a Show Cause Memorandum and imposed preventive suspension effective immediately.
Corpuz explained he believed the caller was authorized, given Metlife’s affiliation and the nature of the inquiry, treating it as intra-office correspondence.
An investigation was conducted and a hearing was held.
On August 6, 2007, Corpuz was informed of the decision to terminate him. His preventive suspension with pay was extended pending final decision.
On August 17, 2007, Corpuz received a Notice of Termination effective August 9, 2007.

Corpuz filed a complaint for illegal dismissal, illegal suspension, unfair labor practice, non-payment of salaries and 13th month pay, and damages.
Citigroup contended the dismissal was due to serious misconduct and willful breach of trust arising from unauthorized disclosure of confidential information. They highlighted Corpuz’s failure to verify the caller and the importance of confidentiality.

The Labor Arbiter (LA) dismissed the complaint, ruling that both the preventive suspension and dismissal were valid for just cause—serious misconduct and willful disobedience.
The LA found ample opportunity to be heard given to Corpuz and ordered payment of pro-rata 13th month pay.

The National Labor Relations Commission (NLRC) affirmed the LA's decision but found the dismissal procedurally infirm for lack of proper notice.
NLRC ordered Citigroup to pay nominal damages and proportionate 13th month pay but did not reinstate Corpuz.
Both parties moved for reconsideration which were denied.

The Court of Appeals (CA) set aside the NLRC ruling and declared Corpuz illegally dismissed.
The CA upheld the preventive suspension but found no serious misconduct justifying termination.
The CA reasoned Corpuz believed the caller was an authorized affiliate and the disclosed information (phone numbers) was not confidential.
The CA found no malice, wrongful intent, or damage caused, and that dismissal was too severe a penalty.
Citigroup's motion for reconsideration was denied.

Whether the Court of Appeals committed reversible error in annulling the NLRC ruling and declaring the dismissal of Corpuz illegal.