G.R. No. 211105 - Del Rosario vs. CW Marketing and Development Corp.

Ruby C. Del Rosario was employed by CW Marketing since 2007, initially as a Sales Consultant and later promoted to Sales Supervisor at the Home Depot, Balintawak Branch.
As Sales Supervisor, Del Rosario was assigned a personal computer connected to a shared network with a printer/scanner; she was uniquely given access and instruction by the company’s IT personnel on how to operate this equipment.

In October 2010, CW Marketing received a report from HSBC alleging that several credit card applicants had submitted falsified payslips and identification cards purportedly issued by CW Marketing’s Balintawak Branch.
An internal investigation by CW Marketing’s IT Department revealed that the documents had been edited and scanned using Del Rosario’s computer, which was the sole device taught to operate the printer/scanner.

On November 4, 2010, CW Marketing issued a Notice to Explain, giving Del Rosario 48 hours to justify her alleged participation in the production of falsified documents involving her subordinates Elaine Hernandez, Mary Rose Cruz, and Jomarie Cayco.
On November 5, 2010, Del Rosario responded via email in which she admitted that she knew her computer was being used by her subordinates (including allowing access to the USB and scanner) but denied involvement in document falsification.
A second Notice to Explain was issued on November 9, 2010, concerning additional violations of the Employee Handbook—specifically, negligence regarding company property (Section 3.5) and unauthorized use of company equipment (Section 3.7).

In subsequent communications, including an email dated November 10, 2010, Del Rosario reiterated that she neither falsified documents herself nor was the sole user of her computer.
On November 18, 2010, during the administrative inquiry, Del Rosario signed the minutes of the meeting and made several admissions:

Acknowledging that the computer assigned to her was her accountability.
Recognizing that while she allowed subordinates to use her computer, she was responsible for any transactions or documents generated.
Admitting that she was the only one granted access to the scanner and that she had been reminded of her supervisory responsibility.
Initially retracting and then reaffirming her stance regarding her non-involvement in the tampering and distribution of documents.

On November 30, 2010, CW Marketing terminated Del Rosario’s employment for violating provisions of its Employee Handbook, holding her liable for allowing access that led to document falsification and for her negligent supervision.
Del Rosario filed a complaint for illegal dismissal before the NLRC, seeking reinstatement and payment of backwages, separation pay, and various other monetary claims.
The Labor Arbiter (LA) initially ruled in favor of Del Rosario, finding her dismissal illegal and ordering payment of backwages and separation pay, though denying other money claims.
CW Marketing and Del Rosario both appealed the LA’s ruling, with CW Marketing challenging the finding of illegal dismissal and Del Rosario contesting the denial of her additional claims.

In its June 6, 2012 decision, the NLRC reversed the LA ruling, holding that Del Rosario was validly dismissed for loss of trust and confidence, citing her negligence in supervising the use of company equipment and the falsification of documents by her subordinates.
The Court of Appeals (CA) affirmed the NLRC’s decision on October 9, 2013, noting that Del Rosario, occupying a sensitive supervisory position, failed to exercise control over her subordinates despite her awareness of their actions.
The CA emphasized that her failure to act on or correct the unauthorized access and use of her company-assigned computer amounted to a breach of trust, justifying her dismissal.

Whether Del Rosario’s dismissal was justified on the ground of loss of trust and confidence given her supervisory role.

Did her allowing subordinates to use her computer and associated equipment, despite having exclusive access, constitute negligence or a breach of her fiduciary duty?
Can an employee be held accountable for the actions of subordinates when the employee acknowledges that others used company property?

Whether Del Rosario’s claims for illegal dismissal and additional monetary benefits were substantiated.

Was there sufficient evidence to demonstrate that her dismissal was executed without just cause?
Did CW Marketing pay deliberated wages and other benefits owed to her aside from the matter of termination?