G.R. No. 169231 - Echevarria vs. Venutek Medika, Inc.

Petitioner: Teofilo Cesar N. Echeverria – former employee of Venutek Medika, Inc., holding the position of assistant marketing manager with a monthly salary of P23,150.
Respondent: Venutek Medika, Inc. – a corporation engaged in the trade and distribution of hospital supplies and equipment and an affiliate of the Dispophil Group of Companies.
The Dispophil Group’s Practice: The various companies in the group hold a joint monthly marketing cut-off meeting to review sales performance and strategize improvements. Sheila Vinuya, an assistant regional sales manager, is responsible for conducting these meetings.

Prior to the May 2, 2002 meeting, petitioner approached Sheila requesting to join the meeting to present his “vision of corporate aonenessa,” which he believed would boost sales for the Dispophil Group.
He also requested that other division heads be invited, a proposal that Sheila found reasonable and approved for a subsequent discussion after the meeting.

Petitioner's actions: He later instructed Lemford Suarez, a product assistant, to invite all product assistants, deviating from his original plan to involve only division heads.
Result: The presence of non-division head employees was noted by Sheila during the meeting, prompting her to clarify the improvised nature of the invitation.

Preparedness: Petitioner came well-prepared with slides and other presentation materials.
Content of the Discussion: His discourse revealed that his vision and mission differed from that of the company.
Controversial Remarks: He made disparaging comments about Assistant Vice President Marlene Orozco, criticizing her character, competency, and performance.

A memorandum dated May 3, 2002, was issued by respondent demanding that petitioner explain in writing why disciplinary action should not be taken, referring to his unofficial participation and his derogatory remarks.
Despite petitioner's explanation that aimed to justify his intentions and deny the disparagement, a second memorandum dated May 7, 2002, charged him with violation of Article 282 of the Labor Code for serious misconduct, commission of a crime or offense, and willful breach of trust.

On May 9, 2002, after deeming his explanation unsatisfactory, respondent served petitioner a letter of dismissal effective immediately.
The very next day, petitioner filed a complaint for illegal dismissal, non-payment of salaries and benefits, damages, and attorney’s fees.

Labor Arbiter Elias H. Salinas: By decision dated January 10, 2003, dismissed the complaint for lack of basis and merit but ordered the respondent to pay petitioner his pro rata 13th month pay for 2002.
National Labor Relations Commission (NLRC): On appeal, reversed the Arbiter’s decision and declared petitioner illegally dismissed, reinstating claims for backwages, reinstatement without loss of seniority, and additional monetary awards.
Court of Appeals Action: In CA-G.R. SP No. 80966, the Court of Appeals set aside the NLRC’s decision and reinstated that of the Labor Arbiter, reversing the appellant’s appeal on reconsideration.

Issue on the extent of review: Whether the Court of Appeals may review and set aside the NLRC’s findings of fact.
Issue on the sufficiency of evidence: Whether there is substantial evidence to support petitioner’s dismissal based on his alleged misconduct.

Whether the Court of Appeals has the jurisdiction to review and set aside the findings of fact made by the NLRC in labor cases, including re-examining the records if necessary to arrive at a just decision.
Whether it is proper for the CA to depart from the NLRC’s factual findings, especially when they conflict with those established by the Labor Arbiter.

Whether there exists substantial evidence to justify petitioner’s dismissal on the ground of serious misconduct, which includes:

The derogatory and injurious statements made about Assistant Vice President Marlene Orozco.
The improper use of a company-sanctioned meeting to air personal grievances under the guise of discussing corporate vision.

Whether petitioner's actions constitute a willful breach of trust and confidence that is serious enough to warrant dismissal under Article 282 of the Labor Code.