G.R. No. 164181 - Nissan Motors Phils., Inc. vs. Victorino Angelo

Victorino Angelo was employed by Nissan Motors Philippines, Inc. (Nissan) on March 11, 1989.
He was part of the payroll staff responsible for preparing company payrolls.
From April 7 to 17, 2000, Angelo was on sick leave and did not prepare payroll for that period.
On April 27 and 28, 2000, Angelo took approved vacation leave for his son's graduation, causing further payroll preparation delays.

Nissan issued a memorandum on May 8, 2000, considering Angelo's dismissal for serious misconduct, willful disobedience, and gross neglect of duties.
Specific allegations included Angelo leaving work early on April 10 (the payroll cutoff date) due to illness, absence without notice on April 11 and April 13, and leaving work early again on April 12.
Attempts to contact Angelo during his absences failed; his home phone was not working.
Due to Angelo’s absence, Nissan's IT department had to access the payroll system, resulting in delayed and inaccurate payroll processing with employees receiving incorrect amounts on April 14 (payday) and complaints from employees.

On April 18, 2000, Angelo was advised to transfer payroll tasks to his immediate superior, agreeing to continue this for two payroll periods (April 30 and May 15).
Angelo took a vacation leave starting April 27 with the condition to complete payroll and turn over tasks before leaving.
Despite several reminders during April 24–26, Angelo did not complete or properly turn over the payroll tasks.
On April 27, the diskette left by Angelo lacked essential data such as account numbers and payroll deductions, causing delays.
On April 28, after collaborative efforts, payroll was released but many employees received significantly less pay due to errors, sparking anger and dissatisfaction.

Angelo failed to report on May 2, 2000, citing illness with delayed notice.
On May 3, he attempted to finish payslips but computed them monthly instead of semi-monthly, causing withholding tax errors and additional employee unrest.
Worker overtime was declined due to payroll problems, severely affecting manufacturing operations and resulting in massive business loss.

Nissan placed Angelo on preventive suspension on May 8, 2000, and held a hearing on May 13.
Angelo filed a complaint for illegal suspension on May 12, later amending it to include illegal dismissal after Nissan issued a termination notice on June 13, 2000.
The Labor Arbiter dismissed Angelo's complaint on September 29, 2000; the NLRC affirmed the dismissal in resolutions dated February 14 and May 13, 2002.
The Court of Appeals (CA) reversed and set aside the NLRC’s decision on March 24, 2004, reinstated Angelo, and ordered payment of backwages.
Nissan filed a petition for review challenging the CA’s ruling.

Whether Nissan’s dismissal of Angelo was for a just cause under Article 282 of the Labor Code.
Whether the Court of Appeals erred in reversing the factual findings of the Labor Arbiter and the NLRC.
Whether Angelo's misconduct, insubordination, and gross neglect of duty justified his dismissal.
Whether Angelo was entitled to reinstatement and backwages despite the just cause for dismissal.
Whether Angelo should be awarded separation pay despite dismissal for just cause due to considerations of equity and social justice.