G.R. No. 251903 - Labastida vs. Quires

Melvin C. Ang was initially employed by IBM Solution Delivery, Inc. as an I.T. Specialist.
During his tenure at IBM, he was assigned to International Container Terminal Services, Inc. (ICTSI) to develop a Business Planning and Consolidation System (SAP BPC).
In November 2012, one month before the expiration of the IBM contract, Ang received an informal job offer from ICTSI to join as SAP BPC Administrator.
Ang resigned from IBM on December 15, 2012, and formally joined ICTSI on January 7, 2013, as part of the Financial Planning System Team.
By June 2013, Ang had been designated as the overall SAP BPC Administrator and later was assigned to the ICTSI Consolidation Team headed by Arlyn McDonald.

On February 22, 2014, Ang informed his superior, McDonald, via text that he intended to take a leave of absence on February 28 and March 3, 2014, and was told they would discuss it the following day.
After taking his planned vacation, upon reporting back to work on March 4, 2014, Ang was served with an unsigned notice to explain regarding alleged infractions.
The notice charged him with several violations including unauthorized absence, failure to complete assigned tasks, incompetence, insubordination, and dishonesty.
Ang submitted his written explanation on March 11, 2014, contesting the legitimacy of the unsigned notice and justifying his actions by stating he had assumed his leave was approved upon the lack of a negative reply.
A second notice, nearly identical to the first but duly signed, was served during a scheduled hearing on March 20, 2014; Ang refused to receive it.
Subsequent to additional administrative hearings and an extension of his suspension (communicated on April 21, 2014), Ang was informed on June 26, 2014 of his dismissal.

On September 23, 2014, Ang filed a complaint before the National Labor Relations Commission (NLRC) for illegal dismissal and various monetary claims including non-payment of wages, service incentive leave, 13th month pay, separation pay, as well as moral, exemplary, and attorney’s fees.
Ang contended his immediate regularization upon hiring, compliance with his duties, and that his leave was taken with the implied consent of his superiors.
ICTSI argued that Ang was dismissed for valid reasons: unauthorized leave during a critical period for the SAP BPC implementation, gross neglect of duty, errors leading to significant operational delays, and a breach of trust consistent with managerial responsibilities.

The Labor Arbiter rendered a decision on August 27, 2015, dismissing Ang’s complaint for lack of merit and upholding the dismissal based on managerial prerogative.
The NLRC partially reversed the Labor Arbiter’s decision on February 29, 2016, awarding backwages, separation pay, and attorney’s fees to Ang, while acknowledging that his unauthorized leave was a misdemeanor that did not by itself merit dismissal.
Both parties moved for reconsideration, with the NLRC’s Resolution on May 23, 2016, affirming its decision—with minor modifications regarding the reckoning of separation pay.
Subsequent appeals were interposed to the Court of Appeals (CA) where, on November 9, 2017, the CA affirmed the NLRC decision with modifications on the computation of separation pay, ordering also the award of service incentive leave and interest on the monetary award.
Motions for partial reconsideration were filed by both Ang and ICTSI but were later denied by the CA in its Resolution on March 22, 2018.

ICTSI elevated issues in a petition for review (G.R. No. 238347), arguing that the CA committed errors in fact and law regarding both the validity of Ang’s dismissal and the procedural due process requirements.
Ang likewise filed a petition for review (G.R. Nos. 238568-69), contending that the CA erroneously omitted his entitlement to backwages and attorney’s fees, and that his dismissal was not substantiated by clear and convincing evidence.
The petitions were consolidated by the Supreme Court for resolution, raising central issues on the validity of his dismissal, due process, and the proper computation of monetary awards.

Whether Ang’s termination was justified based on allegations of gross and habitual neglect of duty and loss of trust and confidence.
Whether the grounds for dismissal properly fall under the just causes provided by the Labor Code, specifically Articles 294 and 297.

Whether Ang was afforded all the necessary procedural due process requirements prior to his dismissal.
Examination of the adequacy and timeliness of notices and opportunities to explain and be heard.

Whether Ang’s employment status as a managerial employee, and thus one holding a position of trust, was correctly established.
Whether the reckoning points for the computation of separation pay and other monetary benefits were correctly applied.

Whether Ang is entitled to backwages, attorney’s fees, and service incentive leave based on the earlier decisions by the LA and NLRC.
Whether ICTSI has satisfied its burden of proof in justifying the dismissal despite the contrary findings by the NLRC and the CA.