G.R. No. L-1866 - Ranjo vs. Payomo

Pardillo was hired in November 1990 as a midwife at E & R Hospital and Pharmacy in Iligan City, which was owned and managed by Dr. Evelyn D. Bandojo (among others).
In 1991, she was transferred to the position of Billing Clerk/Cashier.
In 2001, Pardillo was promoted to Business Office Manager, a position she held until her termination on November 18, 2010.

On November 18, 2010, Pardillo received a Notice of Termination stating that her service as Business Office Manager would end in 30 days from receipt of the memorandum.
The notice cited several causes for her dismissal:

The notice uniquely presented new allegations that were not previously addressed in the earlier Notice to Explain (NTE) and other communications.

Dr. Bandojo asserted that Pardillo had committed several infractions adverse to the hospital’s operations:

Failure to process and send patient records to PhilHealth for refund, resulting in financial losses (citing examples of patients Jamal Alim, Moises Servano, and Stephen Chiu).
Alleged attempt by Pardillo to borrow the hospital’s “Pay to Cash” check for personal use, a check meant for payment of newborn screening kits.
The incident in which Pardillo’s subordinate, Mrs. Natividad Labadan, was observed punching her time card into the bundy clock, suggesting a manipulation of attendance records.

The timing of these alleged infractions ranged from infractions allegedly committed since the early 1990s (with accumulated tardiness) to a notable incident on September 27, 2010.

Following the time-card incident, an administrative investigation was conducted on September 30, 2010, where Pardillo denied the accusations against her.
Pardillo subsequently filed a Complaint for Illegal Dismissal on April 5, 2011, before the Labor Arbiter.

The Labor Arbiter dismissed her complaint on October 24, 2011, holding that she was a managerial employee whose dismissal for loss of trust and confidence was valid based on her infractions.

The NLRC reversed the Labor Arbiter’s decision in its July 31, 2012 Decision, finding that Pardillo’s dismissal lacked both substantive and procedural due process.

The NLRC held that Pardillo was able to explain the alleged infractions and that evidence, such as the flexible work schedule confirmed by the memorandum dated October 30, 2010, mitigated the tardiness allegations.
The NLRC ordered her reinstatement with full backwages but later modified its order to grant separation pay instead when Pardillo manifested strained relations with Dr. Bandojo.

Dr. Bandojo elevated the matter to the Court of Appeals via a petition for certiorari under Rule 65, resulting in the CA reinstating the LA decision that favored the dismissal on the grounds of just cause.

Pardillo brought the petition for review (Rule 45) before the Supreme Court, challenging the CA’s reversal of the NLRC Decision.
Pardillo contended that there were no valid grounds for her dismissal and that due process was not followed, particularly alleging that she did not receive a proper notice to explain regarding the additional charges in the termination notice.

Whether the Court of Appeals committed reversible error in overturning the NLRC Decision, specifically by reinstating the Labor Arbiter’s decision, despite evidence suggesting that Pardillo’s dismissal lacked substantial and procedural due process.
Whether the additional allegations included in the notice of termination—beyond those cited in the earlier NTE—violated the requirement of due process by failing to provide Pardillo a reasonable opportunity to explain or defend herself.