Case Digest (G.R. No. 230597) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ariel M. Reyes v. Rural Bank of San Rafael (Bulacan) Inc. et al., decided on March 23, 2022, petitioner Ariel M. Reyes was the Compliance Officer of respondent Rural Bank of San Rafael (Bulacan) Inc. (RBSR). In 2012, several stockholders discovered that original stock subscription receipts, signed by then-President Flordeliza Cruz, reflected P250.00 to P275.00 per share, while duplicate copies, signed by Treasury Head Emilline C. Bognot or Branch Manager Reynaldo Eusebio Jr., showed only P100.00. The RBSR Board approved a Report on Crimes and Losses and directed Reyes to certify it. Reyes refused, citing lack of independent investigation and insufficient evidence. He was then issued two show-cause orders, preventively suspended, and ultimately terminated for alleged neglect of duty, willful disobedience, and participation in misappropriation. Reyes, Bognot, and Eusebio filed a complaint before the Labor Arbiter (LA) on March 25, 2013, amending it to include illegal dismissal. Case Digest (G.R. No. 230597) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Ariel M. Reyes – Compliance Officer of Rural Bank of San Rafael (Bulacan) Inc. (“RBSR”); petitioner in SC case.
- RBSR and its Board Members (Florante Veneracion, Celerina Sabariaga, Alicia Flor Kabiling, Fidela Manago, Ceferino De Guzman, Rizalino Quintos) – respondents in SC case.
- Factual Antecedents
- In 2012 several stockholders complained of discrepancies between original stock‐subscription receipts (showing P250–P275 per share) and duplicate copies retained by the bank (showing only P100). Investigation confirmed millions of pesos were unaccounted for.
- RBSR’s Board approved a Report on Crimes and Losses and directed Reyes to certify it as required by the BSP regulations (Manual of Regulations for Banks). Reyes refused, claiming lack of independent investigation and insufficient data to validate the report.
- RBSR issued two show‐cause orders to Reyes (charging neglect of duty and later participation in misappropriation), placed him on preventive suspension, and eventually terminated his employment without clear, consistent grounds or strict observance of procedural due process.
- Procedural History
- Labor Arbiter (Feb. 24, 2014): Found Reyes illegally dismissed; awarded backwages, separation pay, benefits, and attorney’s fees.
- NLRC (Sept. 30, 2014): Reversed Arbiter, applied “liberal interpretation” of procedural rules, allowed respondents to submit evidence on appeal, dismissed complaint for lack of merit.
- Court of Appeals (CA) (July 22, 2016; Reciss. Mar. 8, 2017): Denied certiorari petition; affirmed NLRC ruling that respondents were not denied due process and that Reyes was validly dismissed for just cause.
- Supreme Court: Reyes filed a Petition for Review on Certiorari; SC granted review.
Issues:
- Whether the CA erred in affirming the NLRC’s reversal of the Labor Arbiter’s decision.
- Whether Reyes was illegally dismissed by RBSR.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)