G.R. No. 144672 - San Miguel Corp. vs. MAERC Integrated Services Inc.

Respondent Melba S. Sales was first employed by petitioner Litton Mills, Inc. as a weaver on April 22, 1983.
As of September 5, 1999, she was earning a daily wage of P326.29 and was assigned to the Weaving Department.
Her longstanding employment with no previous record of infractions was emphasized by both parties.

On September 5, 1999, at approximately 6:10 a.m., a routine inspection was conducted at Gate 2 of the petitioner’s plant by Security Officer Noel A. Maallo.
During the inspection of employees’ bags—a long-standing security procedure—Maallo discovered two packs of miniature fuse links located in a side pocket and a piece of cloth tape hidden under soiled clothes in Sales’ bag.
It was noted that the fuse links were crucial for the proper operation of machines in the Spinning, Weaving and Finishing Departments.

Petitioner Litton Mills, Inc. accused the respondent of theft of company property and immediately initiated disciplinary action.
On September 6, 1999, Sales was ordered to explain why no disciplinary action should be taken, and she was placed under preventive suspension for fifteen days.
On September 7, 1999, Sales submitted an explanation denying the theft claim, asserting that she was framed-up, and alleged that union officers—particularly Emiliano Salonga and Sonia Mercado—had a motive against her.

A formal investigation was led by Atty. Melvyn S. Florencio, who recommended termination citing theft as an offense under the petitioner’s Offenses Subject to Disciplinary Action (OSDA).
Despite the respondent’s framing defense, detailed testimonies indicated inconsistencies in the evidence presented by her sole witness, Zaida de Asis.
The Labor Arbiter dismissed the respondent’s complaint based on the evidence, a decision later affirmed by the NLRC.

Sales filed a complaint against illegal dismissal with the NLRC, and motions for reconsideration by both parties were denied.
The respondent’s petition for certiorari with the Court of Appeals resulted in the reversal of the NLRC decision, ordering her reinstatement with full back wages and monetary awards.
The petitioner then elevated the case to the Supreme Court on a petition for review on certiorari, contesting the findings of the Court of Appeals.

The petitioner argued that the respondent was caught in flagrante and that the evidence—namely the fuse links and cloth tape—demonstrated theft.
The petitioner maintained that Sales’ voluntary presentation for inspection and her failure to conceal the items bolstered the theft charge.
Conversely, the respondent contended that she was the victim of a frame-up orchestrated by union officers due to her critical stance against the union and its leadership.
The respondent emphasized her long service record and questioned the plausibility of her committing theft under the circumstances.

Whether the petitioner adduced sufficient and clear evidence to establish that Sales stole company property.
Whether the procedural steps taken, including the routine bag inspection and the investigation leading to her dismissal, were adequate and just.

Whether the evidence, particularly the statements of the sole witness Zaida de Asis, was credible and free from inconsistencies.
Whether the burden shifted unfairly to the respondent in a case where the employer must prove theft with clear and convincing evidence.

Whether dismissal was the appropriate remedy given the evidence and the context of Sales’ long and unblemished employment record.
Whether the subsequent offer of separation pay by the petitioner influenced the resolution of the case.

Whether Sales’ claim of a frame-up by union officers holds any merit under the evidence presented.
Whether the alleged motives of union officers were properly substantiated or merely speculative.