G.R. No. L-18062 - Republic vs. Acoje Mining Co., Inc.

Petitioner: House of Sara Lee (technically, Sara Lee Philippines, Inc.), a business engaged in direct selling of assorted merchandise through nationwide outlets.
Respondent: Cynthia F. Rey, employed initially as an Accounts Receivable Clerk and later promoted to Credit Administration Supervisor in the Cagayan de Oro City branch.

The petitioner operates on a system wherein independent dealers—designated as Independent Business Managers (IBMs) or Independent Group Supervisors (IGSs)—purchase merchandise on credit and sell at fixed prices, earning a profit margin and a Service Fee (sales commission) based on sales volume and timely remittance of proceeds.
The company strictly enforces credit terms (38 days for IGSs and 52 days for IBMs) and imposes a penalty, the “Credit Administration Charge,” if remittances are delayed.
The Credit Administration Supervisors (CAS), including the respondent, are tasked with monitoring the credit deadlines, supervising collections, and ensuring compliance with internal policies.

In June 1995, while on temporary assignment in Butuan City, the respondent allegedly instructed a clerk at the Cagayan de Oro branch to extend the credit term of an IBM (her sister-in-law) from the company-mandated 52 days to an unauthorized 60 days.
Subsequent verification by the Branch Operations Manager (BOM), Mr. Jeremiah Villagracia, revealed that similar unauthorized extensions had been routinely made, with some credit terms being extended as far as 90 days.
An internal audit, reinforced by an Auditor’s Report, demonstrated a consistent pattern of credit term adjustments that resulted in undue Service Fee payments and indicated that the practice was contrary to established company policy.

The BOM, after verifying the anomalies, summoned the respondent for an explanation; during the confrontation, she allegedly admitted to the misconduct and pleaded for leniency.
A formal “show-cause” letter was served on June 24, 1995, and the respondent was placed under indefinite suspension.
The respondent submitted an explanation on June 27, 1995 that both denied direct responsibility and attributed the discrepancies to alternative causes—such as deadlines falling on holidays or a broader campaign to increase collections—with indications of inconsistencies in her statements.
A formal hearing was conducted on September 7, 1995, where the respondent’s admissions and the Auditor’s Report further substantiated the irregularities, leading management to initiate disciplinary proceedings.
Based on the hearing and the evidence gathered, the petitioner formally dismissed the respondent on June 25, 1996 for breach of trust and confidence.

The respondent filed a Complaint for illegal dismissal, backwages, and damages on September 24, 1996 before the Labor Arbiter.
On April 30, 1998, the Labor Arbiter rendered a decision in favor of the respondent, awarding backwages, 13th month pay, separation pay, and attorney’s fees, while dismissing other claims.
The petitioner, contesting the administrative findings, appealed to the NLRC and then elevated the issue to the Court of Appeals, which on August 25, 2000 dismissed the petition on the ground that factual issues were not proper subjects for certiorari.
The case reached the Supreme Court via a petition for certiorari under Rule 45, challenging the administrative and appellate decisions on several grounds—including the propriety of reviewing factual determinations and the alleged deviation from established doctrines.

Whether the petitioner validly terminated the respondent’s employment on the ground of loss of trust and confidence in light of the unauthorized credit term extensions.

Did the repeated unauthorized adjustments, as admitted by the respondent and evidenced by the Auditor’s Report, amount to a serious breach of trust expected of a Credit Administration Supervisor?
Is the evidence, including the respondent’s inconsistent admissions, sufficient to uphold the dismissal despite arguments that other employees could access the same computer systems?

Whether the Court of Appeals erred in dismissing the petition for certiorari on the basis that factual issues are not reviewable under Rule 45.

Should factual findings showing repeated deviations from company policy be re-evaluated when they give rise to a clear loss of trust and confidence?
Did the NLRC and CA commit a grave abuse of discretion by failing to consider substantial evidence contrary to their findings?

Whether the disciplinary and administrative procedures followed by the petitioner were proper and whether the respondent’s explanations and purported “standard practice” amount to a valid defense.