G.R. No. 169549 - John Hancock Life Insurance Corp. vs. Davis

Respondent Joanna Cantre Davis was employed as an agency administration officer of petitioner John Hancock Life Insurance Corporation.
On October 18, 2000, Patricia Yuseco, the corporate affairs manager of the petitioner, discovered that her wallet was missing.
Immediately following the discovery, Yuseco reported the loss of her credit cards to AIG and BPI Express, only to learn that fraudulent transactions had been executed using her credit cards.

Patricia Yuseco further learned that substantial purchases had been made in several stores in Manila with her credit cards, and that a proposed transaction at Abenson’s-Robinson’s Place was disapproved due to incorrect verification details.
In response to the rampant loss of personal property within its office, petitioner sought assistance from the National Bureau of Investigation (NBI).
The NBI, during its investigation, obtained a security video from Abenson’s which showed the individual using Yuseco’s credit cards; subsequent identification by Yuseco and other witnesses pointed to respondent as the perpetrator.

Following the identification, the NBI, along with Yuseco, filed a complaint for qualified theft against respondent before the Manila city prosecutor.
The complaint was ultimately dismissed by the city prosecutor due to insufficiency of evidence caused by the improper verification of affidavits presented by the NBI’s witnesses.
Meanwhile, petitioner placed respondent under preventive suspension and directed her to cooperate with the ongoing investigation.

Respondent filed a complaint for illegal dismissal, contending that she was terminated without just cause.
A labor arbiter, in a decision dated May 21, 2002, found that respondent had committed serious misconduct in connection with the alleged theft during work hours, thereby justifying her dismissal.
The National Labor Relations Commission (NLRC) affirmed the labor arbiter’s decision on July 31, 2003, and a motion for reconsideration filed by respondent was denied on October 30, 2003.
Dissatisfied with the NLRC ruling, respondent elevated the matter to the Court of Appeals (CA), asserting that the dismissal was invalid because the city prosecutor had failed to establish probable cause for qualified theft, labeling the charges as mere suspicions.

In its July 4, 2005 decision, the CA observed that both the labor arbiter and NLRC had relied predominantly on the NBI’s findings without independently assessing the evidentiary value of the unverified affidavits.
The CA held that unsubstantiated suspicions, accusations, and employer conclusions did not legally justify dismissing an employee, thereby granting respondent’s petition.

The Supreme Court, however, reversed the CA decision by determining that petitioner had, in fact, substantially proved the valid cause for respondent’s termination.
The Court emphasized that the labor arbiter and NLRC did not merely adopt the NBI’s findings but independently evaluated the evidence, which included affidavits from the NBI witnesses, respondent’s own affidavit, and petitioner’s investigative findings.
The Supreme Court held that although the theft was not committed directly against petitioner, theft by an employee against another person, if proven by substantial evidence, could be regarded as analogous to serious misconduct, thus justifying dismissal.
Consequently, the CA decision reversing the dismissal was set aside and the NLRC and labor arbiter rulings were reinstated.

Whether petitioner substantially proved the existence of valid cause for respondent’s termination.

Whether the evidence presented, including the NBI’s findings and other affidavits, sufficed to establish that the respondent committed an act analogous to serious misconduct.
Whether the technical deficiency in the verification of affidavits, which led to the dismissal of the criminal complaint, should preclude the employer from justifying the dismissal based on theft.

Whether theft, though committed against a person other than the employer, qualifies as misconduct that is analogous to serious misconduct and therefore justifies dismissal under Article 282(e) of the Labor Code.