Facts:

On June 29, 2009, Maria Theresa V. Sanchez was employed by St. Luke's Medical Center, Inc. (SLMC) as a Staff Nurse, primarily assigned to the Pediatric Unit in Quezon City. Her employment was terminated on July 6, 2011, due to alleged violations of SLMC's Code of Discipline, specifically regarding acts of dishonesty, including theft and pilferage. The incident that led to her dismissal occurred on May 29, 2011, when Sanchez was subjected to a standard inspection by security personnel as she exited the hospital. During this inspection, Security Guard Jaime Manzanade discovered a pouch in her bag containing various medical supplies, which were subsequently confiscated. Sanchez requested to return the pouch to the treatment room but was instead taken to the In-House Security Department (IHSD) to explain her possession of the items. She submitted an Incident Report and a handwritten letter of apology, admitting to taking the items, which she claimed were excess stocks fro...

Facts:

Employment and Incident Details
Maria Theresa V. Sanchez was hired by St. Luke’s Medical Center, Inc. (SLMC) as a Staff Nurse on June 29, 2009. She was assigned to the Pediatric Unit in SLMC, Quezon City. On May 29, 2011, at the end of her shift, Sanchez was subjected to a routine inspection at the SLMC Centralization Entrance/Exit. Security Guard Jaime Manzanade noticed a pouch in her bag, which contained various medical items, including syringes, cotton balls, gloves, and other medical supplies. Sanchez claimed the items were excess stocks from discharged patients and were intended for future use in case of shortages.

Investigation and Confession
Sanchez was brought to the SLMC In-House Security Department (IHSD), where she wrote an incident report and submitted a handwritten letter of apology. In the letter, she admitted to knowingly taking the items despite knowing it was prohibited. She explained that she had hoarded the items for future use during shortages.

Disciplinary Actions
SLMC conducted an investigation and placed Sanchez under preventive suspension on June 3, 2011. After a case conference, SLMC terminated her employment effective July 6, 2011, citing violation of the SLMC Code of Discipline, specifically Section 1, Rule 1 on Acts of Dishonesty, which includes theft, pilferage, and misappropriation of funds.

Sanchez’s Defense
Sanchez filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC), asserting that she had no intention of stealing the items and that they were not SLMC’s property. She argued that her handwritten letter was inadmissible as it was made without legal counsel.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Management Prerogative: Employers have the right to prescribe reasonable rules and regulations for the conduct of their business. Employees are duty-bound to obey these rules, and willful disobedience justifies termination.
2. Just Cause for Termination: Sanchez’s actions violated SLMC’s Code of Discipline, which prohibits theft, pilferage, and misappropriation of property, whether belonging to the hospital, employees, or customers. Her deliberate disregard of the rules constituted serious misconduct.
3. Admissibility of Confession: Sanchez’s handwritten letter was admissible as evidence, as it was made voluntarily and not during a custodial investigation requiring legal counsel.
4. Proportionality of Penalty: The Court found that the penalty of dismissal was proportionate to the offense, considering the deliberate nature of the misconduct and the need to maintain discipline in the workplace.
5. Distinction from Criminal Cases: The absence of criminal charges or actual damage to SLMC did not negate the employer’s right to terminate for just cause. Labor and criminal cases are distinct proceedings, and conviction in criminal court is not necessary for dismissal in labor cases.

The Supreme Court reversed the decisions of the NLRC and the Court of Appeals, reinstating the Labor Arbiter’s ruling that Sanchez’s dismissal was valid.