Title
Quiambao vs. Manila Electric Railroad and Light Co.
Case
G.R. No. 171023
Decision Date
Dec 18, 2009
An employee terminated for serious misconduct is ineligible for separation pay due to gross and habitual neglect of duty.
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Case Digest (G.R. No. 171023)

Facts:

  • Arsenio S. Quiambao was employed as a branch teller at Meralco's Mandaluyong office from July 16, 1986.
  • His job involved handling and processing customer payments.
  • Quiambao had a history of misconduct, including excessive absences and poor performance, documented in his employee profile.
  • He faced multiple disciplinary actions, including suspensions and reprimands for tardiness and unauthorized absences.
  • On March 10, 2000, he received a Notice of Investigation for unauthorized absences from November 1999 to February 2000.
  • Quiambao did not attend the investigation, leading to a recommendation for his dismissal for gross and habitual neglect of duty under Article 282 of the Labor Code.
  • He was dismissed effective March 29, 2000.
  • Quiambao filed a complaint with the NLRC on July 3, 2001, challenging his dismissal, claiming his absences were covered by approved leave and that he was denied due process.
  • The Labor Arbiter dismissed his complaint, affirming the legality of his termination.
  • The NLRC awarded him separation pay, citing a precedent case.
  • Meralco contested this decision in the Court of Appeals, which reversed the NLRC's ruling, reinstating the Labor Arbiter's decision and denying Quiambao's claim for separation pay.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled against Quiambao, affirming the Court of Appeals' decision that he was not entitled to separation pay.
  • The Court upheld the findings of the Labor Arbiter and the NLRC regar...(Unlock)

Ratio:

  • The Supreme Court emphasized that the law does not favor employees who engage in serious misconduct.
  • Quiambao's repeated infractions and unauthorized absences showed a blatant disregard for his responsibilities, amounting to gross and habitual neglect of duty.
  • The Court referenced previous jurisprudence, stating that serious misconduct involves a violation of established rules indicative of w...continue reading

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