Case Digest (G.R. No. L-55413) Core Legal Reasoning Model
Facts:
The case involves Dole Philippines, Inc. (Dolefil) as the petitioner and Alfredo Tarroza, Rogelio De la Pena, and Loreto Tejero as the respondents. This case of certiorari was decided by the Second Division of the Supreme Court of the Philippines on July 25, 1983. The events leading to the dispute began on April 29, 1977, when landguards of Dolefil discovered two drums of crude oil in a neighboring farmlot owned by Inocencio Asibal in Pololmalok, South Cotabato. The guards reported their findings to a superior, prompting an investigation that subsequently involved the police. During this investigation, Asibal and his companion Rogelio Odarve each provided sworn statements that implicated the respondents Tarroza, De la Pena, Tejero, and two other employees in the qualified theft of crude oil.
Asibal stated that he purchased crude oil from Tarroza and Tejero on separate occasions, while Odarve made a similar claim against De la Pena. The pilferages were conducted through siphonin
Case Digest (G.R. No. L-55413) Expanded Legal Reasoning Model
Facts:
This case involves the dismissal of three tractor operators—Alfredo Tarroza, Rogelio de la Pena, and Loreto Tejero—of Dole Philippines, Inc. (Dolefil) in Polomolok, South Cotabato, who were accused of siphoning diesel fuel (qualified theft of crude oil) from the tractor tanks while employed on a pineapple plantation. On April 29, 1977, Dolefil’s landguards discovered two drums containing crude oil in a neighboring farmlot, leading to a police investigation. During the investigation, Inocencio Asibal and his companion, Rogelio Odarve, admitted in their sworn statements that they had purchased crude oil from Tarroza, De la Pena, Tejero, and two other employees—transactions allegedly taking place on separate occasions in April 1977.Amid the pending criminal cases filed in the municipal court of Polomolok (Criminal Cases Nos. 1916–1920), Dolefil sought and received clearance from the then Department of Labor to terminate the employment of the implicated workers for "stealing or dishonesty." The workers were suspended on May 13, 1977. Although the municipal court eventually acquitted Tarroza, De la Pena, and Tejero of qualified theft, the company maintained that the evidence (including the confessions of Asibal and Odarve) provided just cause for dismissal. Consequently, when the three workers filed a complaint for illegal dismissal and reinstatement with backwages, the Labor Arbiter dismissed their claim, a decision later set aside by the National Labor Relations Commission (NLRC) on the basis that Dolefil had failed to conduct its own investigation. Ultimately, Dolefil elevated the matter to the Supreme Court via a special civil action for certiorari, contesting the NLRC’s decision and defending its right to terminate the employees based on the loss of employer confidence.
Issues:
- Whether the dismissal of the employees on the ground of “loss of confidence” or serious misconduct can be justified even in the absence of a criminal conviction for the alleged theft.
- Whether the recantation affidavits—submitted after the initial criminal proceedings, which explained the motive behind the witnesses’ earlier statements—could suffice as a basis for reinstatement and backwages, negating the employer’s loss of trust.
- The extent of the employer’s duty to conduct its own independent investigation when a matter has already been referred to, and duly investigated by, the police.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)