Case Digest (G.R. No. 131943)
Facts:
Virginia G. Ramoran v. Jardine CMG Life Insurance Company, Inc., G.R. No. 131943, February 22, 2000, Supreme Court Second Division, De Leon, Jr., J., writing for the Court. The Court considered a petition for review on certiorari of two Court of Appeals resolutions (August 27, 1997 and December 22, 1997) that upheld the dismissal of petitioner Ramoran by a Panel of Voluntary Arbitrators for falsifying overtime (OT) authorization slips in violation of Rule No. 32 of Jardine’s Company Rules and Regulations.Virginia G. Ramoran was employed by Jardine CMG Life Insurance Company, Inc. beginning in 1976 and was a junior accountant in 1994. In December 1993 Ramoran submitted OT authorization slips dated December 6 and December 14, 1993 covering alleged overtime on various November and December dates; Jardine paid the overtime claimed. HRD personnel detected irregularities in those slips (late preparation, alterations, cancellations without initials, and entries appearing to be added later). An internal administrative investigation was held on February 1 and 8, 1994, where Ramoran denied intent to render overtime and claimed she only sought to catch up on backlog; her supervisor, Antonio Robles, denied authorizing the OT and pointed out erasures and missing initials on the slips. On April 4, 1994, Jardine terminated Ramoran for falsifying company records under Rule No. 32.
The Jardine union filed a Notice of Strike with the NCMB (NCMB Case No. NS-05-232-94) and later engaged in strike action. Jardine filed with the Arbitration Board of the NLRC seeking to declare the strike illegal (NLRC NCR Case No. 07-05244-94); that case was dismissed pursuant to a Compromise Agreement between Jardine and the union dated July 22, 1994. Jardine also filed criminal complaints against Ramoran (Criminal Cases Nos. 163751 and 163752) for falsification of private documents; she pleaded not guilty.
Pursuant to a Submission Agreement (March 6, 1995), Jardine and the union submitted the question of whether Ramoran’s termination was for cause and with due process to a Panel of Voluntary Arbitrators. The agreed panel (Atty. Sixto A. Martinez, Jr., chairman; Efren P. Aranzamendez; and Atty. Josephus B. Jimenez) received position papers and decided the case on December 28, 1995, upholding the termination and denying damages. Trial on the criminal complaints began August 29, 1995 and concluded January 15, 1996; on May 14, 1996, Branch 61, MTC Makati convicted Ramoran in one case (No. 163751) and acquitted her in the other (No. 163752), and the conviction was later reversed on appeal by the Regional Trial Court.
Believing the arbitrators’ decision could be overturned following developments in the criminal cases, Ramoran filed a petition for certiorari unde...(Subscriber-Only)
Issues:
- Was certiorari under Rule 65 the proper remedy to assail the decision of the Panel of Voluntary Arbitrators?
- Did the Court of Appeals err by deciding the petition on the merits without requiring the Panel of Voluntary Arbitrators to comment?
- Are the Panel of Voluntary Arbitrators’ findings of falsification supported by substantial evidence so as to justify dismissal despite Ramoran’s acquittal in criminal proceedings?
- Was Ramoran deprived of due process because of the composition and alleged partiality or lack of i...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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