G.R. No. 168215 - LBC Express - Metro Manila, Inc. vs. Mateo

Respondent: James Mateo, designated as a customer associate and regular employee of petitioner LBC Express - Metro Manila, Inc. (LBC).
Petitioners: LBC Express - Metro Manila, Inc. and its vice-president, Lorenzo A. NiaO.

Mateo’s primary job was to deliver and pick-up packages between LBC and its customers.
For these tasks, he was provided with a Kawasaki motorcycle (model 1998, 100 cc, with a book value of P46,000).

Mateo arrived at LBC’s Escolta office at about 6:10 p.m. to drop off packages from various LBC airposts.
He parked his motorcycle directly in front of the office, switched off the engine, and took the key; however, he did not lock the steering wheel.
His failure to secure the motorcycle was allegedly due to his primary concern for the packages—including a large sum of money—to be quickly secured inside the office.
Upon his return three to five minutes later, he discovered that the motorcycle was missing.

Mateo promptly reported the loss to his superiors at LBC and to the nearest police station.
As instructed, he appeared before his superior, LBC’s vice-president Lorenzo A. NiaO, and submitted his explanation regarding the incident.
Following the investigation conducted by LBC, Mateo received a notice of termination dated May 30, 2001 and was barred from reporting for work.

Mateo filed a complaint for illegal dismissal, seeking backwages, reinstatement, and damages.
The labor arbiter, after evaluating the case, found that Mateo was terminated for gross negligence.
The National Labor Relations Commission (NLRC) affirmed the labor arbiter’s decision.
The Court of Appeals (CA) later ruled in favor of Mateo, declaring his dismissal illegal and alleging that due process was not observed.
LBC and NiaO then sought a reversal of the CA decision by petitioning the Supreme Court.

Whether the dismissal of James Mateo was justified considering it was based on the ground of gross negligence.

Did Mateo’s failure to secure the motorcycle, despite clear instructions, constitute gross negligence?
Is habituality a necessary requirement for such dismissal, or is a single act of gross negligence sufficient?

Did the investigation and the notices provided to Mateo (the initial investigation notice and the subsequent notice of termination) meet the requirements of procedural due process under the Labor Code?
Was Mateo adequately informed of the specific allegations (i.e., alleged carnapping of the motorcycle and pilferage of a package) against him prior to his dismissal?

Whether the substantial damage to company property (loss of motorcycle with a book value of P46,000) justified the dismissal.

Can the magnitude of the loss incurred by LBC serve as a sufficient basis to waive the requirement of habituality in cases of gross negligence?