Title
Matis vs. Manila Electric Co.
Case
G.R. No. 206629
Decision Date
Sep 14, 2016
Employees dismissed for tolerating pilferage; SC upheld dismissal due to breach of trust, gross negligence, and substantial evidence.

Case Digest (G.R. No. 206629)

Facts:

Narciso T. Matis, petitioner, vs. Manila Electric Company, respondent, G.R. No. 206629, September 14, 2016, the Supreme Court Third Division, Peralta, J., writing for the Court. Petitioner Narciso T. Matis and fellow crew members (Hipolito, Zuniga, De Guia and Ignacio) were Meralco employees assigned to truck crews; at the time of dismissal Matis was a foreman. On May 25, 2006, a non‑Meralco individual, Norberto Llanes, was observed repeatedly boarding Trucks 1837 and 1891 at a Meralco worksite in Valenzuela, handling and removing materials which did not appear to be returned to company custody.

Meralco’s surveillance team videotaped Llanes’ activity and prepared affidavits. On June 16, 2006 Meralco summoned the crew for investigation; the employees denied involvement. On July 27, 2006 Meralco dismissed Matis and the other crew members for serious misconduct, fraud or willful breach of trust and allied causes, alleging their cooperation or complicity in the pilferage.

Before the Labor Arbiter (LA), Meralco introduced the surveillance video and witness affidavits; the LA (Decision dated April 11, 2007) found the dismissals too harsh and ordered the complainants to report back to work without backwages. The National Labor Relations Commission (NLRC), in a Decision dated July 22, 2009, reversed as to Matis, Hipolito, Zuniga and De Guia (finding valid dismissal for gross negligence and loss of trust and confidence) but ruled Ignacio was illegally dismissed. The Court of Appeals (CA) denied petition for certiorari and affirmed the NLRC in its Decision dated June 11, 2012 (Resolution March 1, 2013). Mat...(Subscriber-Only)

Issues:

  • May the Supreme Court relax the rules and admit petitioner’s late Rule 45 petition for review on certiorari?
  • Was Narciso T. Matis illegally dismissed, or was his dismissal justified by gross negligence and/or loss of trust...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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