Facts:

The case involves Philippine Airlines, Inc. (PAL) as the petitioner and Alendry de Leon as the respondent. The events leading to the case began on September 15, 1995, when PAL received a complaint from Cesar Villanueva, who alleged that he had purchased a round-trip ticket for the Iloilo-Manila-Iloilo route but was unable to obtain a refund for his unused ticket after he opted to travel by boat instead of taking the return flight. Upon investigation, it was revealed that Villanueva's name did not appear on the passenger boarding manifest for the flight he claimed to have taken, and another individual had fraudulently collected a refund for his ticket.

An internal audit by PAL uncovered a scheme involving several employees, including respondent De Leon, who were implicated in the fraudulent refund of tickets. The investigation revealed that the employees had engaged in a conspiracy to defraud the company by manipulating ticket refunds, including issuing new tickets for ...

Facts:

Background of the Case:

• Philippine Airlines, Inc. (PAL) filed a petition seeking the reversal of the Court of Appeals (CA) decision, which found PAL liable for unlawfully terminating Alendry de Leon’s employment.
• The case stemmed from fraudulent refunds of used or flown airline tickets at PAL’s Iloilo Airport Ticket Office.

Investigation of Fraudulent Refunds:

• PAL initiated an investigation after receiving a complaint from Cesar Villanueva, who alleged that his unused Manila-Iloilo ticket was fraudulently refunded.
• The investigation revealed that several employees, including Alendry de Leon, were involved in a scheme to refund tickets that had already been used by passengers.
• The scheme involved:
  • Check-in Clerks failing to properly record and invalidate tickets.
  • Load Control Clerks not logging passenger names in the flight manifest.
  • Ticket Freight Clerks rerouting, reissuing, and affixing revalidation stickers to tickets to facilitate fraudulent refunds.

Administrative Charges:

• PAL filed administrative charges against eight employees, including De Leon, for Fraud, Falsification of Company Documents, and Failure on the Job.
• The employees were dismissed after being found guilty in PAL’s internal investigation.

Labor Arbiter and NLRC Decisions:

• De Leon and others filed complaints for illegal dismissal.
• The Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in favor of PAL, finding substantial evidence of the employees’ involvement in the fraudulent scheme.

Court of Appeals Decision:

• The CA reversed the NLRC’s decision regarding De Leon, ruling that there was insufficient evidence to prove his participation in the conspiracy.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Substantial Evidence of Conspiracy:

   • The Supreme Court found that the NLRC and Labor Arbiter’s findings were supported by substantial evidence.
   • De Leon’s role in rerouting, reissuing, and affixing revalidation stickers to tickets facilitated the fraudulent refund scheme.
   • The affidavits of passengers and documentary evidence confirmed De Leon’s involvement in the anomalies.

2. Conspiracy Inference in Administrative Proceedings:

   • The Court held that conspiracy does not require direct proof in administrative cases. It can be inferred from the employees’ coordinated actions and the nature of their roles.
   • De Leon’s acts, though seemingly routine, were irregular and demonstrated his participation in the scheme.

3. Doubt Resolved in Favor of Labor:

   • The CA erred in applying the principle of resolving doubts in favor of labor, as substantial evidence already established De Leon’s culpability.

4. Valid Grounds for Dismissal:

   • The Court ruled that De Leon’s misconduct constituted a valid and just cause for dismissal under the Labor Code, as it involved fraud and loss of trust and confidence.