Facts:

The case involves Gaudioso Iso, Jr. and Joel Tolentino as petitioners against Salcon Power Corporation (now SPC Power Corporation) and Dennis Villareal as respondents. The events leading to this case began with a series of labor disputes between the petitioners, who were union officers of the Salcon Power Independent Union (SPIU), and the respondent company. In March 2007, a certification election was held, resulting in SPIU being recognized as the employees' collective bargaining agent. However, the respondent refused to recognize the union and did not engage in collective bargaining, leading to a notice of strike filed by SPIU.

On May 27, 2009, during a press conference, petitioners made statements accusing the respondent of financial misconduct, which were subsequently published in a local newspaper. This prompted the respondent to file a criminal complaint for libel against the petitioners and a civil case for damages. Following an investigation, the petitioners we...

Facts:

Background of the Cases
The case involves two consolidated petitions, CA-G.R. CEB-SP No. 02781 and CA-G.R. CEB-SP No. 06429, brought by petitioners Gaudioso Iso, Jr. and Joel Tolentino against Salcon Power Corporation (now SPC Power Corporation) and Dennis Villareal.

CA-G.R. CEB-SP No. 02781
Gaudioso Iso, Jr. and other petitioners challenged the National Labor Relations Commission (NLRC) Decision dated October 11, 2006, which dismissed their claims. Most petitioners entered into Compromise Agreements with SPC Power Corporation, but Iso did not sign any agreement and filed a Motion for Reconsideration, arguing that his claims should not be dismissed since his illegal dismissal case was still pending.

CA-G.R. CEB-SP No. 06429
Iso and Tolentino, officers of the Salcon Power Independent Union (SPIU), accused SPC Power Corporation of refusing to recognize their union and bargained in bad faith. They alleged that SPC's actions were meant to remove them from the union. In 2009, during a press conference, Iso and Tolentino made statements published in Sun Star Cebu, accusing SPC of profiting at the government's expense. SPC filed criminal and civil cases against them for libel and dismissed them for serious misconduct, dishonesty, and breach of trust. The Labor Arbiter (LA) and NLRC upheld their dismissal, finding substantial evidence of their misconduct.

Issue:

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Ruling:

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Ratio:

1. Serious Misconduct as Ground for Dismissal: The Court found that Iso and Tolentino's libelous statements constituted serious misconduct, which is a valid ground for dismissal under Article 297 of the Labor Code. Misconduct must be serious, related to the employee's duties, and performed with wrongful intent, all of which were present in this case.
2. Management Prerogative: The Court upheld SPC’s right to dismiss employees for acts inimical to its interests, especially for supervisory employees who occupy positions of trust and confidence.
3. Procedural Due Process: The Court noted that SPC complied with procedural due process by issuing show-cause notices, conducting hearings, and providing written notices of dismissal.
4. Freedom of Expression and Privileged Communication: The Court rejected petitioners' arguments that their statements were protected by freedom of expression or qualified privilege, as the statements were not made in good faith or in the public interest but were instead defamatory.
5. Weight of Factual Findings: The Court emphasized that factual findings of quasi-judicial agencies like the NLRC, especially when affirmed by the CA, are accorded great respect and finality.