Case Digest (G.R. No. 102692)
Facts:
Petitioners Felix B. Perez and Amante G. Doria were employed by respondent Philippine Telegraph and Telephone Company (PT&T) as shipping clerk and supervisor, respectively, in PT&T’s Shipping Section, Materials Management Group. In 1993, an unsigned letter alleged anomalous freight‐cost transactions, prompting PT&T to form a special audit team. The audit reportedly revealed inflated freight values and tampered duplicate shipping documents. On September 3, 1993, petitioners were placed on a 30‐day preventive suspension, later extended twice by 15 days each on October 3 and October 18, 1993. Without prior notice or hearing, PT&T issued a memorandum dated October 29, 1993, dismissing both for having falsified company documents. Petitioners received that memorandum on November 8, 1993, and filed on November 9, 1993, a complaint for illegal suspension and illegal dismissal before the National Labor Relations Commission (NLRC). The Labor Arbiter ruled the extensions and dismissal illeCase Digest (G.R. No. 102692)
Facts:
- Employment and Anomaly Discovery
- Petitioners Felix B. Perez and Amante G. Doria were employed by Philippine Telegraph and Telephone Company (PT&T) as shipping clerk and supervisor in the Shipping Section, Materials Management Group.
- A special audit, prompted by an unsigned letter, revealed inflated freight costs and tampering, alteration, and superimposition on duplicate shipping documents.
- Disciplinary Proceedings and Procedural History
- Preventive suspension:
- Initial 30-day suspension from September 3, 1993.
- Two extensions of 15 days each on October 3 and October 18, 1993.
- Dismissal: On October 29, 1993, PT&T issued a memorandum dismissing petitioners for falsifying company documents; they received it November 8, 1993, and filed a complaint for illegal suspension and dismissal on November 9, 1993.
- Labor Arbiter’s Decision (December 27, 1995): Found both the 30-day extension and the dismissal illegal; ordered payment of salaries during suspension, reinstatement with backwages and 13th-month pay.
- NLRC Decision: Reversed the Arbiter; held dismissal for just cause with due process and illegal suspension for only 15 days.
- Court of Appeals Decision (January 29, 2002): Affirmed NLRC on just cause and 15-day suspension but ruled that due process was not observed in the dismissal.
- Petition for review: Petitioners challenged the CA decision before the Supreme Court, alleging lack of just cause, absence of due process, and an illegal 30-day suspension.
Issues:
- Just Cause for Dismissal
- Whether PT&T established, by clear and convincing evidence, a just cause based on loss of trust and document falsification.
- Compliance with Due Process
- Whether PT&T observed the two-notice requirement and afforded petitioners a meaningful opportunity to be heard and defend themselves.
- Legality of Preventive Suspension
- Whether the 30-day preventive suspension and its two 15-day extensions were lawful and whether petitioners were properly compensated.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)