G.R. No. 214399 - Puncia vs. Toyota Shaw/Pasig, Inc.

Armando N. Puncia (Puncia) was employed by Toyota Shaw/Pasig, Inc. (Toyota) as a messenger/collector since 2004.
On March 2, 2011, Puncia was appointed as a Marketing Professional tasked to sell seven (7) vehicles monthly.

Puncia failed to meet the sales quota, selling only one (1) vehicle in July and none in August 2011.
Toyota sent a Notice to Explain regarding his failure to meet the quota.
Puncia replied that as a trainee, his quota was three (3) vehicles; May was a lean month; and he sold four (4) vehicles in September.
A hearing was scheduled but Puncia did not appear despite notice, submitting a letter instead.

On October 18, 2011, Toyota dismissed Puncia for insubordination, citing his failure to attend the hearing and justify absence.
Puncia filed a complaint for illegal dismissal, claiming harassment due to his labor union involvement and disputing the grounds for dismissal as insubordination rather than quota failure.
Toyota denied harassment, claimed just cause for dismissal based on failure to meet sales quota and repeated attendance violations backed by disciplinary warnings.

Labor Arbiter (LA) Antonio R. Macam dismissed Puncia’s complaint due to lack of merit but ordered Toyota to pay Puncia his money claims (commissions, 13th month pay, sick and vacation benefits).
LA found Puncia was dismissed for just cause: inefficiency manifested in repeated failure to meet quota and attendance violations, not due to union activity.

The National Labor Relations Commission (NLRC) reversed the LA, declaring Puncia illegally dismissed and entitled to reinstatement and backwages.
NLRC ruled Toyota failed due process:

The written notice did not specify the grounds for dismissal sufficiently.
Grounds for dismissal in the Notice to Explain (quota failure) differed from those in the Notice of Termination (insubordination).

Toyota filed a petition for certiorari before the CA (CA-G.R. SP No. 132615); Puncia filed a similar petition (CA-G.R. SP No. 132674).
CA-Eleventh Division dismissed Puncia’s petition (132674) on procedural grounds but later reinstated it.
CA-First Division denied consolidation and, in the assailed June 9, 2014 Decision, reversed the NLRC and reinstated the LA ruling, validating Puncia’s dismissal for just cause and due process compliance regarding sales quota failure.
Puncia’s motion for reconsideration was denied.

Puncia filed the instant petition contending the CA erred in (1) promulgating its ruling without consolidating the related petitions; and (2) upholding the validity of his dismissal.
Toyota asserted CA-First Division acted properly in issuing the June 9, 2014 Decision since the other petition was dismissed at the time.

Whether the Court of Appeals First Division acted properly in promulgating its June 9, 2014 Decision in CA-G.R. SP No. 132615 without consolidating it with CA-G.R. SP No. 132674.
Whether Puncia was validly dismissed for just cause in compliance with procedural due process.