G.R. No. 267487 - Jose P. Singh vs. Perfecto S. Corpus, Jr. and Marlene S. Corpus

Petitioner Elmer Lopez served as the Branch Manager of Keppel Bank Philippines, Inc. in Iloilo City.
As part of his managerial functions, Lopez was responsible for promoting the bank’s business and nurturing client relationships.

Lopez allegedly issued two purchase orders (POs) for the Hertz Exclusive Cars, Inc. account without authority, totaling P6,493,000.00 for 13 Suzuki Bravos and two Nissan Exalta vehicles.
The bank had a standing directive—stemming from adverse credit findings by its credit committee—to refrain from proceeding with the Hertz loan application.

On August 12, 2003, the bank notified Lopez, requiring him to submit in writing why he should not be disciplined for issuing the unauthorized POs.
Despite his prompt written explanation, the bank disregarded his submission and later terminated his employment through its officers (Manuel Bosano III and Stefan Tong Wai Mun).
A subsequent meeting was held on September 25, 2003, at the bank’s headquarters where Lopez, accompanied by his lawyer and a military officer, attempted to present his side, but the bank reiterated its decision.

Lopez filed a complaint alleging illegal dismissal and money claims, prompting a labor arbitration proceeding.
The Labor Arbiter ruled in April 2004 that Lopez’s dismissal was illegal, ordering his reinstatement and awarding him various monetary reliefs.
On appeal, the National Labor Relations Commission (NLRC) reversed the labor arbiter’s ruling on October 11, 2005, finding that Lopez, by issuing the POs without authority, committed willful disobedience warranting dismissal for cause.
Lopez’s subsequent appeal to the Court of Appeals (CA) in a petition for certiorari was denied on December 19, 2006, and his motion for reconsideration was likewise dismissed on February 7, 2007.

The bank’s appeal before the NLRC was procedurally defective (e.g., lack of a notice of appeal, certificate of non-forum shopping, and certified copy of the appeal bond).
He possessed inherent authority as branch manager to issue POs, as evidenced by past transactions wherein similar orders were paid and even generated profit for the bank.
He was deprived of due process because he was not given a fair opportunity to prepare his defense, having been cornered to provide an explanation immediately.

Lopez’s act of issuing the POs in contravention of a direct order undermined the trust fundamental to his managerial role.
The dismissal was justified under the principle of loss of trust and confidence.
Due process was observed through proper notice and an adequately conducted hearing.

Whether the bank’s appeal before the NLRC was procedurally perfect despite alleged non-compliance with requirements such as filing a notice of appeal, a certificate of non-forum shopping, and furnishing a copy of the appeal bond.

Whether Lopez’s dismissal for cause, based on loss of trust and confidence arising from the issuance of the disputed POs, is justified.
Whether his act of processing the purchase orders despite an explicit directive not to proceed amounts to willful disobedience.

Whether Lopez was afforded adequate procedural due process during the bank’s disciplinary measures and his subsequent dismissal.