G.R. No. 90786 - Salaw vs. National Labor Relations Commission

Petitioner Espero Santos Salaw was employed by Associated Bank in September 1967 as a credit investigator-appraiser.
His duties included inspecting and appraising foreclosed assets, valuing real properties, and verifying the genuineness and titles of mortgaged properties.

On November 27, 1984, the Criminal Investigation Service (CIS) of the Philippine Constabulary extracted from Salaw, without counsel, a three-page Sworn Statement.
The Statement alleged that Salaw and a co-employee sold twenty sewing machines and electric generators foreclosed by the bank for ₱60,000, splitting the proceeds equally (₱30,000 each).

On December 5, 1984, Rollie Tuazon, bank manager, called Salaw to appear before the bank’s Personnel Discipline and Investigation Committee (PDIC).
A hearing was scheduled for February 28, 1985 at 11:00 a.m., “without counsel or representative.”
On April 1, 1985 (effective March 27, 1985), Salaw was dismissed for “serious misconduct or willful disobedience and fraud or willful breach of trust.”

April 17, 1985: Salaw filed a complaint for illegal dismissal with the NLRC (NCR-4-1272-85), and recanted his CIS Sworn Statement.
March 29, 1988: Labor Arbiter Villarente declared the dismissal illegal and ordered reinstatement with backwages.
July 26, 1989: NLRC reversed the arbiter’s decision and dismissed the case for lack of merit.
October 31, 1989: NLRC denied petitioner’s motion for reconsideration.
Petitioner filed a petition for certiorari with the Supreme Court.

Whether the petitioner’s dismissal was for a valid or authorized cause under the Labor Code.

Whether the petitioner was afforded the twin requirements of notice and hearing, including the right to counsel, before dismissal.