Case Digest (G.R. No. 184452)
Facts:
Lufthansa Technik Philippines, Inc., Antonio Loquellano and Arturo Bernal v. Roberto Cuizon, G.R. No. 184452, February 12, 2020, the Supreme Court Second Division, Hernando, J., writing for the Court.Petitioners are Lufthansa Technik Philippines, Inc. (LTP) and several of its officers and supervisors; respondent is Roberto Cuizon, formerly MA2 Duty Manager at LTP’s Cebu (Mactan) station. Cuizon had 32 years’ service with Philippine Airlines’ Maintenance and Engineering Department which was later absorbed by LTP. On March 10, 2005, during an A01 engine check on PAL aircraft EI‑BZE, mechanics observed a flame about 1.5 meters long and suspected an accidental engine “light‑up.” Cuizon, then Duty/Project Manager, ordered cooling and later towed the aircraft to the MA2 hangar and continued checks; he reported the condition in terms that petitioners claim concealed the accidental light‑up. On April 15, 2005, while supervising an A12 check/towing of PAL RP‑C4008, the aircraft struck a utility post, damaging LH wing flaps; petitioners alleged Cuizon had taken the headset from the licensed headset man, assigned an inexperienced substitute, left the crew, and failed to ensure safety precautions and tower clearance.
LTP investigated, served show‑cause memoranda, and on August 9, 2005 issued a memorandum finding Cuizon guilty of safety violations, negligence, false information and dismissing him effective August 16, 2005. Cuizon filed an illegal dismissal complaint with the NLRC (initially NLRC RAB‑VII), and on May 4, 2006 the Labor Arbiter rendered a decision declaring respondents not guilty of illegal dismissal but ordering payment to Cuizon of P79,691.42 for 13th/14th month pay and commutation of leave credits. The NLRC affirmed the Labor Arbiter on March 6, 2007; its denial of Cuizon’s reconsideration followed on June 27, 2007.
Cuizon filed a Rule 65 petition for certiorari with the Court of Appeals (CA), which treated the matter as questioning grave abuse of discretion by the NLRC. In CA‑G.R. SP No. 02998 the CA, in a March 5, 2008 Decision, reversed the NLRC and Labor Arbiter, held Cuizon’s dismissal illegal, and ordered separation pay and full backwages in addition to the amounts already awarded. The CA denied petitioners’ motion for reconsideration on September 5, 2008.
Petitioners filed a Rule 45 petition for review on certiorari with the Supreme Court raising essentia...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly determine that the NLRC acted with grave abuse of discretion such that the CA could review and overturn its factual findings?
- Was respondent Roberto Cuizon validly dismissed for loss of trust and confidence?
- Was respondent Roberto Cuizon validly dismisse...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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