Case Digest (G.R. No. 110844) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves Lepanto Consolidated Mining Company (Petitioner) and a group of employees led by Maximo C. Mamaril (Respondent). Mamaril was hired as a security guard on November 14, 2003, and later assigned to the Security Reaction Force (SRF), which was responsible for special security duties without pulling out posted guards. The SRF members were required to be on duty 24/7, receiving additional compensation in the form of free rice, extra pay, and overtime.
On October 8, 2006, Mamaril was on duty when he was accused of complicity in the theft of skinned copper wires by a mine employee, Eliseo Sumibang. Security Guards Arthur Bangkilas and Romeo Velasco reported that Mamaril opened a security gate which allowed Sumibang to escape with the stolen goods. Following the incident, both Mamaril and Sumibang were placed under preventive suspension.
An internal investigation led to Mamaril's dismissal for what Lepanto characterized as qualified theft and breach of trust. Mama
Case Digest (G.R. No. 110844) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Employment
- Lepanto Consolidated Mining Company (petitioner) hired Maximo C. Mamaril (respondent) as a security guard on November 14, 2003.
- Mamaril was initially assigned to the Security Reaction Force (SRF), a unit created by retired Col. Wilhelm D. Doromal composed of 14 ex-military personnel.
- Members of the SRF were required to be on duty and on call 24/7, posted alternately to sensitive areas, and confined mostly to company premises except on scheduled rest days.
- The SRF received additional benefits including a rice supply, housing, an extra rate of P20, and overtime compensation equivalent to one hour’s pay per day.
- The Incident on October 8, 2006
- At approximately 7:25 p.m., security operatives Arthur Bangkilas and Romeo Velasco, while on surveillance duty, apprehended two individuals at the Tubo Collar gate of Lepanto Mine Division in Sapid, Mankayan, Benguet.
- Eliseo Sumibang, Jr., an employee working as a mucker, was caught for stealing skinned copper wires, and Mamaril—the guard on duty—was also apprehended for allegedly opening the man door to facilitate the removal of the wires.
- The security officers produced a Spot Report and a Joint Affidavit stating that, positioned about 40 meters away in low-light conditions, they witnessed Mamaril open the gate and observed activity lasting about one minute during which a tricycle (plate no. AP-1586) was involved in transporting the pilfered items.
- Physical evidence recovered included approximately 110.45 kilograms of skinned copper wires wrapped in muddy burlap sheets.
- Mamaril’s Defense and Subsequent Investigations
- During the formal hearing held on October 16, 2006, Mamaril denied any involvement or conspiracy in the theft, admitting only that he had failed to secure the man door by not padlocking it.
- Mamaril asserted that at the time of the incident he was on roving patrol, having been reassigned from the SRF to regular security duty effective August 20, 2005 (as evidenced by Office Order No. 14-2005).
- Several witnesses including mechanics and security personnel testified (through affidavits) to having seen Mamaril on roving duty elsewhere, thereby supporting his alibi.
- Lepanto’s internal investigations, including an Investigation Report dated October 19, 2006, and a subsequent legal resolution dated November 4, 2006, found Mamaril guilty of qualified theft, leading to his dismissal for dishonesty and breach of trust.
- Administrative and Judicial Proceedings
- On November 21, 2006, Mamaril filed a complaint with the National Labor Relations Commission Regional Arbitration Branch (NLRC RAB-CAR) for illegal dismissal, seeking full backwages, separation pay, overtime pay, rest day pay, damages, and attorney’s fees.
- Additional complaints were filed by other security guards (members of the original SRF and reassigned personnel) seeking overtime, night shift differentials, holiday pay, and related benefits, arising largely from their work during a strike (June 2 – September 11, 2005).
- The three separate cases were consolidated and, in a Joint Decision issued on March 4, 2008, the Labor Arbiter ruled in favor of Lepanto regarding Mamaril’s dismissal on the grounds of loss of trust and confidence, while denying the monetary claims due to insufficient evidence regarding overtime or holiday work.
- On appeal, the NLRC later reversed part of the earlier ruling in a Resolution dated January 8, 2010, declaring that Mamaril’s dismissal was without just cause and awarding him separation pay and full backwages, while also granting claims for overtime, holiday, and rest day pay for some private respondents.
- A subsequent Resolution on August 13, 2010, further modified the awards to include additional overtime, holiday, and rest day pay for the various respondents.
- Lepanto then elevated the case by filing a petition for certiorari under Rule 65, which resulted in a Court of Appeals (CA) Decision on October 21, 2015, affirming the NLRC’s modified rulings and awarding the respective monetary benefits.
- A Motion for Partial Reconsideration by Lepanto was filed and ultimately denied by the CA on June 28, 2016, leading to the petition filed in this case.
Issues:
- Whether the appellate court committed reversible error in ruling that:
- Mamaril was dismissed without just and valid cause and, therefore, entitled to separation pay and full backwages.
- Mamaril and the other respondents were entitled to compensation for work rendered on overtime, holiday, and rest days.
- Whether the evidence presented (particularly the affidavits of Bangkilas and Velasco regarding the alleged act of opening the man door) was sufficient and credible to sustain the dismissal for loss of trust and confidence.
- Whether Lepanto’s reliance on its internal investigative report and the assumption of Mamaril’s alleged participation in a conspiracy was legally and factually justified.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)