G.R. No. 209735 - People vs. Tequillo

Petitioner: Stanfilco – a division of DOLE PHILIPPINES, Inc., a domestic corporation operating a banana plantation in Lantapan, Bukidnon.
Respondent: Jose Tequillo – a Farm Associate who was employed from January 5, 2004 until his termination on May 24, 2010.
Co-worker involved: Resel Gayon – the employee who was assaulted by Tequillo.

Stanfilco regularly held an employee gathering titled “Kaibigan Fellowship” that, besides being social, also served as a venue for company announcements and production updates.
The gathering was held during work hours and on company premises.

Tequillo deliberately opted not to attend the mandatory “Kaibigan Fellowship” and instead went to the farm shed area with several fellow workers to drink.
Resel Gayon, who was sent to assist Tequillo at an assigned area of the plantation, encountered the drinking group and was eventually persuaded to join them.
Tension escalated when Tequillo, already resentful due to petitioner’s refusal to grant him a productivity incentive, warned Gayon about the consequences of not meeting performance expectations.
Upon Gayon suggesting that Tequillo air his grievances to higher-ranking employees, Tequillo, provoked by the suggestion, proceeded to maul him.

On September 15, 2009, petitioner issued a memorandum requiring Tequillo to explain his conduct regarding the assault and the drinking incident.
During administrative hearings held on October 17, 2009 and February 2, 2010, Tequillo was given the opportunity to explain his version of the events; he admitted to mauling Gayon but claimed his act was in self-defense, while remaining silent on the drinking charge.
The explanations provided were deemed unsatisfactory, leading the petitioner to terminate Tequillo on May 24, 2010 for serious misconduct.

Tequillo filed a complaint for illegal dismissal on October 6, 2010.
On January 31, 2011, the LA ruled in favor of the petitioner, concluding that the drinking and fighting incident constituted serious misconduct amounting to willful disobedience.

On August 24, 2011, the NLRC reversed the LA’s decision declaring the dismissal illegal, determining that the incident was not work-related since Tequillo was not performing his official work at the time.
The NLRC ordered Tequillo’s reinstatement and awarded backwages and attorney’s fees.

The petitioner sought relief before the CA through a petition for certiorari.
On June 14, 2013, the CA affirmed the NLRC resolution, ruling that no grave abuse of discretion was committed by the NLRC when it declared the dismissal illegal.
A motion for reconsideration was denied by the CA on October 14, 2013.

Tequillo’s act of drinking during work hours and subsequent mauling of Gayon clearly contravened internal disciplinary rules which prohibited alcohol consumption on company premises during working hours.
The “Kaibigan Fellowship,” being part of working time, meant that the incident was inherently work-related.
Due to the deliberate and wrongful nature of the act and its connection with his job performance (failure to meet work quotas and grievance over productivity incentive), Tequillo’s actions amounted to serious misconduct warranting dismissal.

Whether the CA erred in ruling that no grave abuse of discretion attended the NLRC’s decision which declared Tequillo’s dismissal illegal.
Whether the act of physical violence (mauling a co-worker), despite occurring on company premises during working hours, can be intrinsically deemed work-related.
Whether the evidence sufficiently established that Tequillo’s act was connected to his work duties and performed with wrongful intent, thus constituting serious misconduct.
Whether the proper legal standard in determining work-relatedness should consider the proximate cause or motive behind the incident rather than just the time and place of its occurrence.