Facts:

The case involves Manila Memorial Park Cemetery, Inc. (MMPCI) and its executive vice-president Enrique B. Lagdameo as petitioners, against Delia V. Panado as the respondent. The events leading to the case began when Delia V. Panado was employed as a Park Information Officer at MMPCI's memorial park in Sucat, Parañaque, earning a monthly salary of P10,300. Her responsibilities included attending to clients' needs, arranging interments and cremations, handling park collections, and remitting these collections to the bank or cashier. In February 2000, Panado arranged tent rentals for the Obice family for a death anniversary and later for the So family in May 2000. An internal audit by MMPCI revealed discrepancies in the rental payments, prompting Lagdameo to issue a memorandum to Panado on July 19, 2000, requesting an explanation for her alleged failure to remit the rental payments.

In her response dated July 21, 2000, Panado claimed she did not receive any payments f...

Facts:

Employment Background:

• Petitioner Manila Memorial Park Cemetery, Inc. (MMPCI) is a corporation engaged in developing and maintaining memorial parks in the Philippines.
• Petitioner Enrique B. Lagdameo is MMPCI's executive vice-president and chief operating officer.
• Respondent Delia V. Panado was employed by MMPCI as a Park Information Officer at its Sucat, Parañaque memorial park, earning a monthly salary of P10,300.00. Her duties included handling customer needs, arranging interments, managing tent rentals, and remitting park collections.

Incident Leading to Termination:

• In February 2000, respondent arranged tent rentals for the Obice family for a death anniversary event. In May 2000, she coordinated tent and chair rentals for the So family.
• An internal audit revealed discrepancies in the services rendered and payments received. Specifically, it was found that the Obice family had paid for tent rentals, but the payment was not remitted to MMPCI.
• On 19 July 2000, petitioner Lagdameo issued a memorandum to respondent, asking her to explain why she failed to remit rental payments for certain transactions.

Respondent’s Explanation:

• In her 21 July 2000 response, respondent denied receiving any payments. She explained that the So family was allowed free use of the tent due to a family connection with her supervisor, Julius Munar. Regarding the Obice family, she stated that they had promised to pay but failed to follow through.
• Erlinda Obice, the wife of the deceased, later certified that she had paid the rental fee, which was received by Aguilar Santiago, another MMPCI employee, who then remitted it to Sonny Brequillo.

Termination:

• On 25 August 2000, respondent was terminated for "gross and habitual neglect of duties" and "willful refusal to follow specific instructions" related to tent rental policies.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Fraud or Willful Breach of Trust: The Court found no evidence that respondent appropriated company funds. The payment from the Obice family was handled by another employee, and the So family’s rental was free. Thus, the termination based on fraud or breach of trust was unjustified.
2. Negligence: While respondent admitted negligence in failing to follow up on payments, this did not meet the standard of "gross and habitual neglect" required under Article 282(b) of the Labor Code. Her actions were not willful or intentional.
3. Proportionality of Penalty: The Court emphasized that the penalty of dismissal must be proportionate to the offense. Given respondent’s long service and the minor nature of the infraction, reinstatement with backwages was the appropriate remedy.

Conclusion:

The Supreme Court upheld the Court of Appeals' decision, ordering respondent’s reinstatement with full backwages, as the grounds for her dismissal were not supported by substantial evidence and the penalty was disproportionate to her infractions.