G.R. No. 156283 - Philippine National Construction Corp. vs. Matias

Rolando Matias was first employed on July 16, 1975 by the Construction and Development Corporation of the Philippines (CDCP) as Chief Accountant and Administrative Officer.
In 1981, he was transferred to the company’s main office as Head of the Corporate Accounting Department.
In 1984, following the conversion of CDCP’s loans to equity (which transformed the company into a government-owned or controlled corporation and led to its renaming as Philippine National Construction Corporation (PNCC)), Matias availed himself of a retrenchment program on December 31, 1984.

During his earlier employment, several parcels of land in Don Carlos, Bukidnon, were placed in employees’ names as trustees for corporate agricultural purposes, with subsequent internal arrangements to transfer the properties back to the corporation.
A notable incident involved a land parcel of 117,750 square meters registered under Matias’ name on April 24, 1980 (Original Certificate of Title No. P-11315).
In July 1992, two former CDCP employees, Reynaldo Tac-an and Luciano Tadena, visited Matias at his residence with documents and Special Power of Attorney, informing him that the lands (including the one registered under his name) were under the Comprehensive Agrarian Reform Program (CARP) and had been invaded by squatters.
Against his better judgment, Matias signed the necessary documents and, six months later, acknowledged receipt of a P100,000.00 payment.
On December 18, 1992, the Register of Deeds for Bukidnon cancelled the Original Certificate of Title and issued a new Transfer Certificate of Title (No. T-36141) in the name of the Republic of the Philippines, facilitated by payments and bonds from the Land Bank of the Philippines.

Matias was rehired by PNCC on August 12, 1996 as Project Controller in the PMMA Project in Zambales, later heading the Core Group at the Central Office in Mandaluyong City.
In September 1997, based on a presentation by Mr. Felipe C. Alday—the Head of the Realty Management Group—Matias was shown a listing of properties and informed that the transaction for the land registered under his name (OCT No. P-11315) had not been fully compensated by the Land Bank.
Acting on Alday’s representation, Matias executed a Deed of Assignment on September 16, 1997, thereby reassigning the property to PNCC for a consideration of P5,900.00, and warranting in writing that the property was free from any lien or encumbrance.
In April and June 1998, following a memorandum from PNCC’s Administration Division (through Ms. Janice Day E. Alejandro), Matias was required to submit an explanation regarding issues of falsification, estafa, dishonesty, and breach of trust and confidence arising from the deed.
On June 1, 1998, subsequent to demands for an explanation and a suggestion for resignation in lieu of termination, a letter was served advising him of termination effective June 15, 1998.
As a result, Matias filed a complaint for illegal dismissal and money claims against PNCC on July 8, 1998.

The Labor Arbiter (LA) found in favor of Matias, determining that his dismissal was illegal, and ordered his reinstatement along with awards of back wages and attorney’s fees.
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, holding that Matias had omitted material information regarding previous payments from the Land Bank, thereby justifying the dismissal for loss of trust and confidence.
The Court of Appeals (CA) later reversed the NLRC decision, reinstating the LA’s disposition by holding there was insufficient evidence to justify dismissal on the grounds of breach of trust, and noting that PNCC had acted anomalously by assigning properties to various employees to evade CARP.

Whether the petition filed before the Court of Appeals (CA) should be given due course despite being filed one day late, in light of the principles of substantial justice and equity.

Whether Rolando Matias was illegally dismissed given that the termination was predicated on the allegation of loss of trust and confidence.
Whether the alleged loss of trust was supported by sufficient and substantial evidence, particularly considering that the representation by PNCC’s officer (Mr. Felipe Alday) induced him to execute the Deed of Assignment.

Whether the CA erred in completely disregarding NLRC’s findings that Matias was guilty of a breach of trust by failing to disclose previous payments and by signing documents without proper authority or full disclosure.
Whether the CA’s decision properly applied the legal principles concerning the burden of proof in cases of dismissal for loss of trust and confidence.