G.R. No. 147031 - Electruck Asia, Inc. vs. Meris

In 1977, the International Rice Research Institute (IRRI), an international organization recognized by the Philippine government, hired Nestor B. Micosa as a laborer.
As part of his employment, Micosa was bound by IRRI’s Employment Policy and Regulations, which included a provision stating that an employer may dismiss an employee convicted of a criminal offense involving moral turpitude.

On February 6, 1987, Micosa stabbed to death Reynaldo Ortega inside a beer house in Los Baños, Laguna.
Shortly thereafter, on September 15, 1987, Micosa was formally accused of the crime of homicide.
During the pendency of the criminal case, Micosa voluntarily applied for inclusion in IRRI’s Special Separation Program.

On January 9, 1990, IRRI’s Director General, Klaus L. Lampe, disapproved Micosa’s special separation application, expressing the institute’s desire to retain his skills and talents.
On January 23, 1990, the trial court found Micosa guilty of homicide but noted mitigating circumstances, namely incomplete self-defense and voluntary surrender, as well as the absence of any aggravating circumstance.
Subsequently, Micosa applied for suspension of his sentence under the Probation Law.

On February 8, 1990, the IRRI Director General issued a personal letter confirming Micosa’s status as a regular core employee. This letter stated that his appointment was for an indefinite period and that he “may not be terminated except for justifiable causes as defined by the pertinent provisions of the Philippine Labor Code.”
On March 30, 1990, IRRI’s Human Resource Development Head, J.K. Pascual, urged Micosa to resign due to his conviction for homicide.
On April 22, 1990, further correspondence from Pascual charged Micosa with violating the institute’s Personnel Manual on the ground that his conviction for homicide involved moral turpitude.
Micosa responded on April 27, 1990, arguing that his actions were in self-defense, that his conviction should not be deemed as involving moral turpitude, and that he opted to forgo appeal in order to secure the benefits of probation.
On May 7, 1990, Micosa sought assistance from IRRI’s Grievance Committee, which recommended his continued employment.

Despite favorable evaluations, on May 21, 1990, Micosa received a notice from J.K. Pascual terminating his employment effective May 25, 1990.
Micosa filed a case for illegal dismissal on May 29, 1990.
Labor Arbiter Numeriano D. Villena, on August 21, 1990, rendered a decision finding the termination illegal, ordering Micosa’s reinstatement to his former position and the payment of full backwages from the date of dismissal.
On January 31, 1991, the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, albeit with the deletion of the award for attorney’s fees.

Whether the NLRC had acted with grave abuse of discretion by holding that IRRI lacked the authority to prescribe dismissal reasons not enumerated in Article 282 of the Labor Code.
Whether IRRI committed grave abuse of discretion by relying on its Personnel Manual in dismissing Micosa solely on the ground that his conviction for homicide involved moral turpitude.

Its prerogative to promulgate rules and regulations, including disciplinary measures, allowed it to raise standards beyond those in the Labor Code.
Maintaining high standards was necessary not only for internal efficiency but also to honor its obligations as an international organization in the host country.

Notwithstanding, IRRI had previously assured Micosa of job security by confirming his status as a regular core employee and specifying that he could not be terminated except for just causes under the Labor Code.

Whether the conviction of a crime involving moral turpitude constitutes a valid ground for dismissal under an employer’s internal personnel regulations, especially when such grounds are not specifically enumerated in Article 282 of the Labor Code.
Whether Micosa’s conviction for homicide, committed under mitigating circumstances of incomplete self-defense and voluntary surrender, can be classified as involving moral turpitude.
Whether IRRI’s decision to dismiss Micosa, based solely on the alleged moral turpitude of his conviction for homicide and notwithstanding assurances given to him regarding employment security, is a legally justifiable exercise of its disciplinary prerogative.