G.R. No. 118860 - Pono vs. National Labor Relations Commission

Petitioner Rolinda B. Pono was employed by Sandoz Phils., Inc. as a medical representative with the primary task of updating doctors about the company’s various medical products.
Pono’s employment status and responsibilities positioned her under the immediate supervision of Rafaelito I. Castillo.

On May 18, 1992, Pono was summoned by her supervisor Castillo to his office to explain alleged incompetence regarding her work performance.
During the meeting, Castillo initiated unwanted physical advances by touching various parts of her body, which Pono resisted.
Castillo warned her not to disclose the incident, intimating that any disclosure could jeopardize her continued employment.

For approximately five months, Pono remained silent and maintained a façade of normalcy despite the incident.
On October 5, 1992, during another meeting called under the guise of discussing company matters, Pono, fearing a repeat of the harassment, disclosed the May 18 incident to her closest co-workers.
Accompanied by co-workers, Pono reported the incident to Sandoz’s National Sales Manager, Godofredo Ruiz, which led to further administrative attention.

On October 6, 1992, Ruiz convened a meeting to hear Castillo’s side of the incident; Castillo denied the sexual harassment allegations.
Ruiz initially advised Pono not to resign until she had settled certain financial obligations (amortizations on the company car), though the offer was later withdrawn.
Castillo subsequently shifted focus to discussing alleged work inefficiencies, leading Pono to submit a handwritten explanation on October 14, 1992.

Shortly after her written response, Pono’s services were formally terminated, a decision that was backed by development of documented discrepancies in her work reports and repeated violations of company policies.
Pono filed a complaint alleging illegal dismissal, unfair labor practices, sexual harassment, non-payment of separation pay, and damages.
Concurrently, criminal charges for attempted rape and acts of lasciviousness were filed against Castillo, though these were later dismissed by the Prosecutor’s Office due to lack of merit.

Pono’s version centered on the sexual harassment incident, asserting that her dignity and rights were violated and that she was forced to choose between her job and exposing the misconduct.
The respondents contended that Pono’s dismissal was warranted based on a pattern of inefficiencies, discrepancies in her work (including alleged forgery of call cards), and repeated violations of company policies, portraying her complaint as a fabrication intended to forestall her dismissal.

The Labor Arbiter dismissed Pono’s complaint for lack of merit, and the decision was subsequently affirmed by the National Labor Relations Commission (NLRC).
Despite the evidence of alleged just cause, questions regarding procedural irregularities, particularly the absence of a proper hearing before her termination, were raised.
Pono petitioned the Court for annulment of the NLRC decision, contending grave abuse of discretion and violation of due process.

Whether Pono’s dismissal was substantively justified by a valid or just cause based on the factual records and company policies.
Whether Sandoz Phils., Inc. observed the constitutional and procedural requirements of due process, including the necessity of a proper hearing before termination.
Whether the alleged sexual harassment incident, as claimed by Pono, ought to have been given credence or reconsidered in the context of her dismissal.
Whether the NLRC erred in affirming the dismissal decision by disregarding the due process violations alleged by Pono, despite acknowledging that the dismissal was for just cause.