G.R. No. 152166 - St. Luke's Medical Center, Inc. vs. Notario

On June 23, 1995, respondent Estrelito Notario was employed by St. Luke’s Medical Center, Inc. (petitioner hospital) as an In-House Security Guard.
In August 1996, Nimaya Electro Corporation installed a closed-circuit television (CCTV) system at petitioner hospital to enhance security. An orientation seminar on proper monitoring was conducted for in-house security personnel, subject to certain guidelines.

On December 30, 1996, respondent was on duty from 6:00 p.m. to 6:00 a.m. monitoring video cameras.
That evening, Justin Tibon reported the loss of his traveling bag, containing airline tickets, passports, and other belongings, from room 257 where his daughter was admitted.
The hospital’s Security Department reviewed the CCTV tapes for the relevant period and found that the video recorder focused only on cameras monitoring the Old and New Maternity Units, failing to record any incident of the theft at room 257.

On January 6, 1997, petitioner hospital issued a memorandum directing respondent to explain in writing within 24 hours why disciplinary action should not be taken against him for violating the rotation/sequencing of the CCTV monitoring.
Respondent explained he was alone on duty and focused on high-crime areas (Old and New Maternity Units) based on his judgment.
Finding the explanation unsatisfactory, petitioner hospital issued a Notice of Termination dated January 24, 1997, dismissing respondent for gross negligence/inefficiency under its Code of Discipline.
On March 19, 1997, respondent filed a complaint for illegal dismissal seeking reinstatement with full backwages and other benefits.

The Labor Arbiter dismissed respondent’s complaint, ruling that respondent was negligent in focusing cameras only on maternity units and that his infraction exposed petitioners to potential damage suits.
Respondent appealed. The NLRC reversed the Labor Arbiter’s decision and found no proof of a required Standard Operating Procedure (SOP) on camera focusing. It characterized respondent’s actions as a single, isolated instance of simple negligence, not justifying dismissal. The NLRC ordered respondent’s reinstatement with backwages and separation pay in case reinstatement was no longer feasible.
Petitioners’ motion for reconsideration was denied by the NLRC.

On September 21, 2001, the Court of Appeals affirmed the NLRC’s decision, holding that even assuming negligence, dismissal was not proper due to the lack of habitual negligence, absence of pecuniary damages, and failure to comply with due process (twin notice rule and hearing).
Petitioners filed the present petition for review on certiorari, asserting that respondent’s gross negligence warranted dismissal, that a single act of negligence is sufficient cause, and that there was compliance with due process.

Whether or not the dismissal of respondent for gross negligence in the monitoring of the CCTV cameras was valid and supported by just cause under Article 282 (b) of the Labor Code.
Whether or not petitioners complied with the procedural due process requirements, specifically the twin notice rule and the right to hearing, in effecting respondent's dismissal.
Whether or not respondent is entitled to reinstatement and backwages or to separation pay in lieu of reinstatement.