Case Digest (G.R. No. L-61232-33)
Facts:
The case involves San Miguel Corporation as the petitioner and the Deputy Minister of Labor and Employment, Regional Director Dioscora Arellano, and Bienvenido Soto as the respondents. The events leading to the case began on April 11, 1950, when Bienvenido Soto was employed by San Miguel Corporation as a field warehouseman. Over the years, he received numerous awards and commendations, including the title of 'Salesman of the Year,' and was promoted to District Sales Supervisor, earning a monthly salary of P1,940.00, along with various allowances. However, on January 16, 1978, Soto was relieved of his duties pending an investigation into his alleged involvement in the cash refunding of condemned shells.
On August 29, 1978, Soto filed a complaint against the company for preventive suspension, illegal dismissal, and illegal salary deductions. The case revolved around allegations that Soto had failed to destroy condemned shells as instructed and instead facilitated cas...
Case Digest (G.R. No. L-61232-33)
Facts:
Employment Background
- Bienvenido Soto was employed by San Miguel Corporation (SMC) on April 11, 1950, as a field warehouseman. Over the years, he received awards, commendations, and promotions, eventually becoming a District Sales Supervisor with a monthly salary of P1,940.00, plus allowances.
Preventive Suspension and Allegations
- On January 16, 1978, Soto was relieved of his duties pending an investigation into his alleged involvement in the "cash refunding of condemned shells." SMC filed a report with the Ministry of Labor on August 29, 1978, detailing Soto's preventive suspension, illegal dismissal, and illegal deduction of salary.
Specific Allegations
- Soto, as District Sales Supervisor, was responsible for condemning "shells" (empty wooden cases used for packing soft drink bottles). He was accused of:
- Ordering the condemnation of 700 shells in Calapan, Mindoro, on November 21, 1977, but only 300 were destroyed.
- Ordering the condemnation of 680 shells on November 23, 1977, but only 228 were destroyed.
- Ordering the condemnation of 600 shells on December 21, 1977, but only 480 were destroyed.
- Allegedly, Juan Burgos, the Salesman-in-Charge of Calapan Sales Office, cash-refunded the condemned but undestroyed shells, raising P4,860.00, which he allegedly gave to Soto.
- Similar allegations were made regarding the Pinamalayan Sales Office, where Ruperto Refria, the Salesman-in-Charge, allegedly refunded P1,360.00 to Soto.
Company’s Grounds for Termination
- SMC sought clearance to terminate Soto based on falsification of company documents, abuse of authority, and unauthorized removal of company records.
Regional Director’s Decision
- Regional Director Dioscora Arellano granted clearance to terminate Soto, citing loss of trust and confidence. However, SMC was ordered to pay Soto either retirement pay or separation pay of one-half month’s pay for every year of service.
Appeal to the Ministry of Labor
- Both parties appealed. The Deputy Minister of Labor, Vicente Leogardo Jr., set aside the Regional Director’s decision and ordered Soto’s reinstatement with three years of backwages without qualification.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Loss of Trust and Confidence as Ground for Termination:
- Loss of trust and confidence is a valid ground for dismissal, especially for employees holding positions of responsibility. Proof beyond reasonable doubt is not required; it is sufficient if there is "some basis" for such loss of confidence.
- Soto, as a District Sales Supervisor, held a position requiring full trust and confidence. His alleged involvement in the misappropriation of company funds and breach of trust justified his termination.
Due Process:
- The Court found that the Regional Director and Deputy Minister sufficiently considered the evidence, meeting the standards of due process. However, the Deputy Minister’s conclusions were not supported by the facts.
Jurisdiction:
- The Court did not find merit in SMC’s argument that the Deputy Minister lacked jurisdiction. The case was properly within the jurisdiction of the labor authorities.
Reinstatement and Backwages:
- The Court disagreed with the Deputy Minister’s order for reinstatement with backwages, as Soto’s actions warranted termination due to loss of trust and confidence.
Conclusion:
- The Supreme Court reinstated the Regional Director’s decision, allowing Soto’s termination with payment of either retirement or separation pay. The Court emphasized that loss of trust and confidence, especially for high-ranking employees, justifies dismissal without requiring proof beyond reasonable doubt.