G.R. No. 173137 - Bases Conversion Development Authority vs. DMCI Project Developers, Inc.

Joyce Anabelle L. Orpilla (respondent) was employed by Stradcom Corporation (Stradcom) on November 15, 2001, as Head of the Human Resources Administration Department (HRAD) under probationary status for six months, with a monthly salary of ₱60,000.
Her duties included administrative and training matters.

On January 2, 2003, Jose A. Chua (Chua), President and CEO of Stradcom, issued a memorandum announcing the reorganization of the HRAD:

The Training Section was to be spun off and included in Business Operations, renamed Human Resources Training and Development, reporting to the Chief Operating Officer (COO).
Personnel and Administration were to report to the Chief Financial Officer (CFO).
Respondent and the Training Section were to report directly to COO Ramon G. Reyes.

After turning over HRAD documents and equipment, respondent inquired about her status, to which Chua replied management had lost trust and confidence in her and suggested resignation. Respondent declined, demanding formal charges, which were not presented.
On January 9, 2003, respondent was offered a settlement through Chua’s Chief Legal Officer, Atty. Eric Gene Pilapil; she was advised to take leave and think it over, with assurance of continued salary.
On January 13, 2003, respondent reported for work but was refused entry and advised to take leave.
Respondent received her last salary on January 15, 2003, including pro-rated 13th month pay, after which no payments were made.
Respondent claimed constructive dismissal from January 2, 2003, converted to actual dismissal on January 15, 2003.
On June 29, 2003, respondent filed for constructive dismissal with claims for backwages, attorney’s fees, and damages.

Petitioners contended that respondent, as HRAD Head, failed in duties during the 2002 Christmas party preparations:

Against instructions, she excluded employees of affiliate Land Registration Systems, Inc. (Lares) from the party.
They discovered overpriced catering costs: respondent stated ₱250 per head, but actual price was ₱200.
Investigation revealed respondent misused company resources, including preparation of training materials for non-company purposes during overtime and Sunday work.

Respondent denied the allegations but was notified of loss of trust and confidence due to willful disobedience and breach of trust.
Respondent initially indicated willingness to resign but later withdrew the resignation.
Petitioners insisted dismissal was with just cause and proper due process.

On September 30, 2003, the LA ruled respondent was illegally dismissed and ordered Stradcom and Chua liable for separation pay, backwages, moral and exemplary damages, and attorney’s fees amounting to ₱847,000 (subject to computation).
The LA found that due process requirements were violated.

On July 30, 2004, the NLRC partially granted petitioners’ appeal, ruling respondent was validly dismissed for loss of trust and confidence due to mishandling of the Christmas party budget.
Respondent was awarded unpaid salaries for January 16 to April 16, 2003, and attorney’s fees amounting to ₱214,500.
The NLRC denied relocation to reinstatement, indicating formal notification of dismissal occurred only on April 16, 2003.
NLRC denied reconsideration on April 20, 2005.

On September 28, 2012, the CA reversed the NLRC, reinstating the LA’s ruling declaring illegal dismissal.
The CA denied petitioners’ motion for reconsideration on April 17, 2013.

Petitioners filed a Petition for Review on Certiorari before the Supreme Court challenging the CA decision.

Whether the Court of Appeals erred in reversing the NLRC decision and ruling that petitioners illegally dismissed respondent as HRAD Head.

Whether respondent willfully disobeyed lawful and reasonable instructions.
Whether respondent committed fraud, misrepresentation, dishonesty, and other acts inimical to petitioners’ interests.
Whether respondent engaged in moonlighting and improper use of company personnel and resources.

Whether the CA erred in finding that respondent was demoted without due process.

Whether Jose A. Chua may be held jointly and severally liable with Stradcom for any monetary award.