G.R. No. 262600 - People vs. AAA

Petitioner Ma. Wenelita Tirazona, an Administrative Manager of Philippine EDS Techno-Service, Inc. (PET), filed a petition seeking reconsideration of the Court’s earlier decision affirming her termination.
The case stems from a dispute regarding her dismissal, where she challenged the legality of her termination, demanded separation pay, and sought retirement benefits under existing laws.

Tirazona held a managerial position which inherently involved a high degree of trust and confidence reposed in her by her employer.
As a managerial employee, her role required discretion and adherence to the company’s internal protocols, particularly in matters involving rank-and-file employees.

PET officers and directors reprimanded her for improper handling of a situation involving a rank-and-file employee.
In response, Tirazona claimed she was denied due process and demanded an exorbitant indemnity of P2,000,000.00 from the company and its officers/directors.
Notably, she admitted to reading a confidential letter containing the legal opinions of PET’s counsel, which was addressed to PET’s officers/directors, thereby breaching the trust reposed in her.

The National Labor Relations Commission (NLRC) and the Court of Appeals found her to be in breach of the trust placed in her, supporting her termination on the grounds of managerial misconduct.
The Court, in its Decision dated 14 March 2008, subscribed to these factual findings and upheld the termination, emphasizing her arrogance, hostility, and uncompromising stance.

On 29 April 2008, Tirazona moved for reconsideration of the earlier decision, arguing that the Court failed to consider her alleged long service (initially claimed to be twenty-six years, later corrected to eight years) with PET.
The Court issued a Resolution dated 23 June 2008, denying the Motion for Reconsideration for lack of substantial arguments.
On 21 August 2008, she filed a Motion for Leave to File a Second Motion for Reconsideration, incorporating her previous arguments yet raising essentially the same issues.

PET was duly given the opportunity to comment on the second motion, and it filed its opposition on 19 November 2008.
Tirazona subsequently filed a Reply on 8 December 2008.
The Court, after thorough scrutiny, found that the second motion was unmeritorious and prohibited under Section 2, Rule 52 of the Rules of Court, given that a second motion for reconsideration is not allowed unless extraordinary persuasive reasons are presented.

Whether the termination of Tirazona’s employment was justified, given her conduct and the breach of trust inherent in her actions.
Whether her reading of a confidential letter and her subsequent actions constituted sufficient grounds for dismissal.

Whether Tirazona, despite being in a managerial position dismissed for cause, is entitled to separation pay and retirement benefits.
Whether the length of her service, as argued in her motions, should have been taken into account in awarding such benefits.

Whether the filing of a second motion for reconsideration, which reiterates previously raised arguments, is procedurally permissible under the Rules of Court.
Whether any extraordinarily persuasive reason existed to warrant the consideration of her second motion for reconsideration.