Case Digest (G.R. No. 148105)
Facts:
Francisco Reyno v. Manila Electric Company, G.R. No. 148105, July 22, 2004, Third Division, Sandoval‑Gutierrez, J., writing for the Court.Petitioner Francisco P. Reyno was hired by respondent Manila Electric Company (MERALCO) on August 1, 1969 and rose to Assistant Squad Leader of Squad 12 in the Inspection Department. Squad 12 inspected customer electric meters to ensure accurate metering and to apprehend tampering; MERALCO implemented an incentive scheme paying inspectors an extra 30‑minute overtime pay for each report of a major violation they submitted.
In July 1987 MERALCO's Special Presidential Committee (SPC) investigated alleged illegal connections at the Daig Kaku Restaurant; during that inquiry several Squad 12 members (Tadeo Santiago, Carlos Cruz, July Capundan, Danilo Teodoro and Edwin Dancel) gave declarations implicating petitioner — they said Reyno instructed them to prepare false inspection reports (e.g., to report shunted wires or loose potential links when none or different facts existed) and to favor certain customers. Clarificatory hearings were set for September 14 and 21, 1987; petitioner's counsel failed to appear and the SPC proceeded. The SPC found Reyno guilty of dishonesty, serious misconduct and willful breach of trust and MERALCO terminated his employment effective November 4, 1987.
Reyno filed for illegal dismissal and related claims with the Labor Arbiter (NLRC NCR Case No. 00‑02‑01093‑89). The Labor Arbiter dismissed the complaint on August 2, 1993, finding just cause for dismissal and that due process was observed. The NLRC First Division reversed on August 18, 1994 and ordered reinstatement with backwages, but on January 11, 1995 the First Division reconsidered and set aside its reversal, upholding the Labor Arbiter and dismissing Reyno's complaint. After motions and re‑raffling the case, the NLRC Second Division on April 22, 1999 reinstated the August 18, 1994 decision — ordering reinstatement but without backwages.
MERALCO then filed a petition for certiorari with the Court of Appeals (CA) on July 27, 1999. On January 17, 2001 the CA reversed the NLRC Second Division and reinstated the NLRC First Division's January 11, 1995 decision upholding Reyno's dismissal. The CA found that (1) proceedings before the Labor Arbiter are non‑litigious so strict application of the Rules of Evidence is not required and the absence of live witnesses did not deny Reyno due process, and (2) substantial evidence supported dismissal for dishonesty and willful breach of trust. The CA denied Reyno's motion for reconsideration on May 3, 2001.
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Issues:
- Was petitioner deprived of his right to cross‑examine the witnesses Carlos Cruz, Danilo Teodoro and Edwin Dancel before the Labor Arbiter?
- Was petitioner’s dismissal without just cause despite the NLRC Second Division’s April 22, 1999 decision finding ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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