Title
Reyes vs. Rural Bank of San Rafael , Inc.
Case
G.R. No. 230597
Decision Date
Mar 23, 2022
Ariel Reyes, RBSR Compliance Officer, refused to certify a report on stock subscription anomalies, leading to his dismissal. SC ruled his termination illegal due to lack of due process and valid cause.

Case Digest (G.R. No. 230597)
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)

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