Case Digest (G.R. No. 98137)
Facts:
Philippine Rabbit Bus Lines, Inc. v. National Labor Relations Commission, G.R. No. 98137, September 15, 1997, Supreme Court Second Division, Mendoza, J., writing for the Court. Petitioner is Philippine Rabbit Bus Lines, Inc.; respondents are the National Labor Relations Commission, Hon. Labor Arbiter Rolando D. Gambito, and private respondent Reynato B. Aguinaldo (a former bus conductor).Private respondent worked as a conductor whose duties included issuing passenger and freight tickets and collecting fares. On September 18, 1988, while assigned to Bus No. 575 (Baguio–Manila), he issued a freight ticket based on a bill of lading presented by the freight clerk for a load of flowers. Inspectors later found two passengers without tickets and eight flower bundles unaccounted for; Aguinaldo issued tickets then and paid for an additional freight ticket from his own funds. He was placed under preventive suspension the same day; a company memorandum dated September 20/21, 1988 informed him of the suspension and required him to report within three days for investigation.
An investigation was held on September 26, 1988, at which Aguinaldo admitted the alleged violations. After more than 30 days of suspension, Aguinaldo returned to work but was denied admission; a termination notice dated April 11, 1989 was served on him on May 3, 1989. On April 26, 1989 he filed a complaint for illegal dismissal.
The Labor Arbiter rendered a decision on December 20, 1989 finding petitioner guilty of dismissing Aguinaldo without just cause and denying due process, ordering reinstatement and backwages (or separation pay if reinstatement impossible), and awarding attorneys’ fees. Petitioner appealed to the NLRC which, in its October 29, 1990 decision, affirmed the Labor Arbiter but modified the relief to reinstatement with one year backwages an...(Subscriber-Only)
Issues:
- Was the company’s memorandum and investigatory process a sufficient compliance with the requirements of procedural due process in dismissing Aguinaldo?
- Did petitioner have just cause to dismiss Aguinaldo for serious misconduct, gross and habitual neglect of duties, or willful breach of trust?
- What is the appropriate remedy — reinstatement with backwages, separation pay, or other relief — given th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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