G.R. No. 167810 - Republic vs. Rambuyong

Bernie Llorente was hired in November 2007 by Metro Psychiatry, Inc. (MPI) as a nursing attendant.
MPI is a domestic corporation engaged in full service psychiatric care and rehabilitation services.
Llorente’s employment was marked by prior infractions such as being caught sleeping on duty and being absent without leave, as well as reports of discourteous behavior toward patients.

On June 22, 2016, Llorente was served a memorandum from MPI, requiring him to explain why disciplinary action should not be taken against him for continuously refusing to perform certain assigned tasks.
In his Explanation Letter, Llorente defended his actions and alleged mistreatment by MPI.
On July 9, 2016, MPI’s subsidiary, NIPI, served him another memorandum noting:

Allegations of falsely informing a patient’s parent that the patient was being maltreated.
Non-compliance with the assistant nursing attendant head’s instructions to clean the facility and attend endorsement meetings.

The incident involving a patient named David Warren Tan occurred on March 17, 2016, when the patient’s mother received a text message from someone claiming to be a former staff member alleging physical abuse at MPI.
CCTV footage later showing Llorente examining patients’ charts and copying information—which he pocketed—became a crucial piece of evidence.
Llorente, in his Explanation Letter also on July 9, 2016, denied contacting Tan’s mother and claimed that he was merely copying vital signs for endorsement; he further contended that cleaning duties were not within his job description.

On September 5, 2016, Llorente received a Notice of Termination citing loss of trust and confidence and willful disobedience as the grounds for his dismissal.
In response, Llorente filed a complaint for constructive dismissal, arguing that MPI had subjected him to harassment and discriminatory practices, including:

Reduction in work days.
Assignment of tasks like refilling water and cleaning that were not part of his regular duties.
False accusations regarding communication with Tan’s parents.

MPI countered Llorente’s claims by emphasizing that his misconduct included historical issues such as being tardy, sleeping on duty, and being generally discourteous, and maintained that his misconduct, including falsely alerting Tan’s family, warranted dismissal.

The LA dismissed Llorente’s complaint for lack of merit.
It clarified that Llorente was terminated, not having resigned, rejecting claims of constructive dismissal.
The LA emphasized that other employees were also tasked with similar duties, thus dismissing the harassment and discrimination allegations.
Substantial evidence, such as eyewitness testimony and Llorente’s own actions, supported his termination.

The NLRC affirmed the LA’s decision on the legality of Llorente’s dismissal.
However, it modified the LA ruling by awarding Llorente unpaid salary for six days, service incentive leave, salary differential with double indemnity, and holiday pay.

The CA reversed the NLRC and LA decisions, holding that the evidence presented was inadequate to justify Llorente’s termination.
It contended that the handwritten witness statements and the nature of Llorente’s actions (viewed as within the scope of his routine access to patient records) did not amount to serious misconduct.
The CA reduced the severity of the penalty regarding his disobedience to warrant only a simple reprimand rather than termination.

MPI filed a petition for review on certiorari before the Supreme Court challenging the CA’s findings.
The petition sought to reverse the CA’s decision and reinstate the termination ruling, arguing that the evidence supported Llorente’s misconduct.
A motion for reconsideration by MPI was denied in a CA Resolution dated February 12, 2019.

Whether the Court of Appeals erred in its finding that MLM’s evidence was insufficient to sustain Llorente’s termination from employment.

Whether the CA’s reliance on handwritten witness statements and its interpretation of the CCTV footage failed to appreciate the gravity of Llorente’s misconduct.
Whether the reversal of the decisions of the Labor Arbiter (LA) and the National Labor Relations Commission (NLRC) was justified, given the substantial evidence presented against Llorente.
Whether the proper standard of substantial evidence was applied in determining the legitimacy of MPI’s decision to terminate Llorente’s employment.