G.R. No. 203984 - People vs. Calantiao y Dimalanta

On November 14, 1996, respondent Adonis A. Pionilla was hired by Integrated Microelectronics, Inc. (IMI) as a production worker.
Pionilla enjoyed a long, unblemished record with the company, having rendered nine years of service prior to the incident.

On May 5, 2005, Pionilla received a notice from IMI to explain an incident that occurred the previous day.
The incident involved Pionilla escorting a woman—who appeared to be a job applicant but was in possession of a company identification card—to board the company shuttle bus at the Alabang Terminal.
It was later discovered that the lady was using the company ID as a free pass, which was against company protocol.
Pionilla admitted that he had lent his company ID to the woman, who turned out to be his relative, explaining that the act was intended to save on transportation expenses.

A Conscience Committee was convened by IMI to investigate the incident.
During the committee hearing, Pionilla admitted that he possessed two IDs in his name: a temporary ID obtained after losing his original in November 2004, and the original ID he had previously lost.
The possession and use of two IDs, together with the act of lending the ID, were considered a breach of security protocols as outlined in the Company Rules and Regulations (CRR).

Pionilla was found to have violated Article 6.12 of the CRR, which expressly forbids the lending of company IDs.
Based on this violation, IMI issued a letter of dismissal on August 16, 2005, effective the following day (August 17, 2005).

Three days after his dismissal, Pionilla filed a complaint for illegal dismissal with damages against IMI.
On May 17, 2007, the Labor Arbiter (LA) rendered a decision finding Pionilla to have been illegally dismissed, ordering his reinstatement and the payment of full backwages amounting to P417,818.78.
The LA noted that Pionilla’s actions did not result in a breach of the security of company premises and were influenced by a mistaken notion of camaraderie and gratitude.
Dissatisfied with the LA’s ruling, IMI elevated the case to the National Labor Relations Commission (NLRC), which on June 30, 2008, reversed the LA’s decision by validating the dismissal, emphasizing that the act of lending the temporary ID was willful and intentional.
Pionilla then sought relief by filing a petition for certiorari before the Court of Appeals (CA), which on July 28, 2011, granted his petition. The CA found that while IMI’s ID regulations were reasonable, the penalty of dismissal was excessively harsh given Pionilla’s long and unblemished service record.
IMI sought reconsideration of the CA ruling, but the motion was denied in a resolution dated January 16, 2012, and a subsequent petition for review on certiorari was also denied with a resolution dated January 14, 2013.

IMI filed a motion for reconsideration, contending that awarding Pionilla full backwages along with reinstatement was excessive and contrary to established principles.
The Court, while acknowledging the illegality of the dismissal, ultimately modified its resolution to delete the award of backwages in favor of Pionilla based on selected exceptions to the general rule.

Whether the Resolution dated January 14, 2013 should be reconsidered in view of IMI's contention.

IMI argued that granting full backwages in addition to reinstatement would be excessive and unfair.
The contention further emphasized potential conflict with existing legal principles and established jurisprudence regarding remedies for illegal dismissal.

Whether the exceptions to the general rule on reinstatement and full backwages—particularly in cases of overly harsh penalties and in instances where the employer acted in good faith—apply to the present case.