G.R. No. 78090 - Pacific Mills, Inc. vs. Alonzo

Zenaida Alonzo was employed by Pacific Mills, Inc. as a ring frame operator from July 30, 1973 until her discharge on September 30, 1982.
The dismissal was effected by the company’s management without a prior formal investigation, complaint, or hearing.

On September 22, 1982, in the early afternoon, Zenaida engaged in a physical altercation with Company Inspector Ernesto Tamondong.
During the altercation, she verbally provoked him using abusive language and physically assaulted him by boxing him in the stomach.
The immediate cause of the assault was her resentment over a prior reprimand given to her, along with other employees, for wasting time due to engaging in idle chatter.

Zenaida was terminated via a memorandum from the company’s Executive Vice President & General Manager effective October 1, 1982.
The stated grounds for her dismissal included:

The company justified immediate dismissal citing a provision in its Rules and Regulations (as embodied in the Collective Bargaining Agreement) which stipulated that fighting or attempting to inflict harm to another employee warranted outright dismissal.

Zenaida filed a complaint for illegal dismissal and non-payment of her proportionate 13th month pay on October 4, 1982 before the NCR Arbitration Branch.
During this arbitration hearing, Pacific Mills, Inc. presented evidence not only of the assault but also of her repeated violations of company rules.
The Labor Arbiter found that:

Zenaida had indeed verbally abused and physically struck her superior.
Her prior infractions were well-documented and undisputed by her.
Despite confirming the act, the penalty imposed (suspension for three months) was deemed harshly mitigated relative to the infraction committed.
The company had failed to conduct a proper investigation prior to her dismissal.

The Labor Arbiter ordered the reinstatement of Zenaida with backwages and the payment of her 13th month pay (P351.00), considering both the misconduct and the failure to observe due process.
The NLRC, on appeal by the employer, affirmed the Arbiter’s findings but limited the back wages award to three years, in line with previous Supreme Court decisions.
Pacific Mills, Inc. filed a special civil action of certiorari in the Supreme Court seeking to nullify the NLRC decision, arguing that the dismissal was justified by cumulative infractions and that reinstatement was not appropriate.

The Solicitor General opined that the dismissal should be viewed in light of the totality of the employee’s infractions rather than the isolated incident of assault.
He recommended the payment of separation pay equivalent to three years’ back wages (without reinstatement) along with proportionate 13th month pay.
The NLRC’s Chief Legal Officer and the private respondent maintained that due process was not observed in the dismissal, justifying the reinstatement award.
The en banc decision in Wenphil Corporation v. NLRC was cited, emphasizing that while due process is mandatory, reinstating an employee who is demonstrably undesirable could demoralize the workforce and adversely affect the employer’s interests.

Whether or not Zenaida Alonzo’s dismissal was justified given the series of infractions, including the assault on her superior.

The challenge centered on whether the immediate discharge was warranted solely on the basis of the assault or should be viewed in the context of her overall poor work conduct and repeated rule violations.
The issue also involved the question of whether, despite the justified cause for dismissal, due process requirements had to be strictly observed.

Whether Pacific Mills, Inc. complied with the mandatory procedural requirements in dismissing Zenaida.

Specifically, the inquiry involved the lack of a formal notice of the charges and a consequent hearing before her dismissal.
The question arose as to what sanctions should be imposed on the employer for failing to comply with due process norms.

The controversy encompassed whether reinstatement with backwages, given the misconduct, was proper public policy.
Comparison with the punitive and disciplinary measures in Wenphil Corporation to determine if reinstatement would serve justice and protect the employer’s interest.