G.R. No. 165960 - Torreda vs. Toshiba Information Equipment , Inc.

Jeffrey O. Torreda was initially engaged by Toshiba Information Equipment (Phils.), Inc. as a finance assistant on a probationary basis on July 1, 1997, handling tasks such as payroll processing and bookkeeping for T&P Properties, Inc.
Effective January 1, 1998, he was confirmed as a regular finance accountant under the Finance and Accounting Department, reporting to Vice-President Kazuo Kobayashi and Finance Manager Teresita Sepulveda.
His responsibilities included processing payrolls, maintaining year-to-date earnings and tax reports, preparing vouchers for payroll-related accounts, handling tax payments and returns, and preparing government reportorial requirements.

On May 22, 1998, Torreda and four other co-employees reported to Senior Vice-President Hisao Tanaka that Finance Manager Sepulveda had ordered them to prepare petty cash vouchers in their names, allegedly for her personal use.
Following this, management imposed restrictions on Sepulveda’s authority, including barring her from approving petty cash vouchers beyond ₱1,000.00 and requiring her to submit monthly reports on these vouchers.

On July 22, 1998, Sepulveda accessed Torreda’s personal computer and read his personal communications, including the report he had sent to Tanaka about her conduct.
In response, Torreda sent an e-mail to Tanaka expressing his discontent, asserting that his personal files were accessed without his consent and reminding management that similar intrusions had occurred previously by Sepulveda.

Sepulveda subsequently filed a complaint against Torreda with Human Resources regarding alleged repeated tardiness during the period from April to July 1998.
On August 27, 1998, Sepulveda ordered him to compile a summary of payroll overpayments dating back to October 1996, a period prior to his employment, which he contested as inappropriate.

From September 1 to 3, 1998, in response to complaints from separated employees regarding their final salary claims and from incumbent employees about various benefits, Sepulveda, with prior approval by Kobayashi, had Torreda’s office drawer—containing payrolls and Social Security records—forcibly opened by Ruben delos Santos, a staff member from the General Administration Section.
The act was carried out in the presence of several Finance Department employees, and the documents retrieved were later used to process the claims.

On September 7, 1998, Sepulveda requested that Torreda surrender his drawer key for duplication purposes, which Torreda refused, arguing that there was no basis for such a request.
Torreda’s response came in the form of an e-mail accusing Sepulveda of "robbery" for forcibly opening his drawer and alleging the misappropriation of ₱200.00 from his personal drawer, which was circulated to other company officials, including Tanaka, Cristobal, Kobayashi, and Noralyn Florencio.

On September 7, 1998, a conference was held in Kobayashi’s office involving Torreda, Cristobal, and Sepulveda. Torreda maintained that he was not informed about the necessity of opening his drawer, while Sepulveda contended that she did not have his contact numbers to notify him.
An investigation led by Maximo Dones on September 8, 1998, found no basis to support Torreda’s claim of robbery.
The Human Resources Department issued a written warning to Torreda on September 10, 1998 regarding his tardiness, and on September 11, 1998, he was directed to submit a written explanation for alleged insubordination.

After refusing to explain his actions adequately and subsequently contesting Sepulveda’s authority in an e-mail that outlined additional allegations of misconduct against her (including abusive behavior, unauthorized access, falsification of records, and more), the situation escalated.
Even though Sepulveda approved his paternity leave (September 12–21, 1998), Torreda’s failure to submit the required explanation led to further disciplinary measures.
On October 2, 1998, the General Administration Department recommended his dismissal on the ground of grave slander, given his baseless yet public accusation against Sepulveda.

On October 14, 1998, Torreda received a termination letter from Gerardo C. Cristobal, Jr., Senior Manager of HRA, citing his grave slander—characterized by his written allegation of robbery against Sepulveda—as the justified cause for dismissal.
On March 23, 1999, Torreda filed a complaint for illegal dismissal. The Labor Arbiter initially ruled in his favor, ordering reinstatement with backwages.
However, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision on November 15, 2002, by upholding the dismissal as being for just cause.

Dissatisfied with the NLRC ruling, Torreda filed a petition for certiorari before the Court of Appeals on April 1, 2003, alleging grave abuse of discretion on part of the NLRC.
The Court of Appeals dismissed the petition, maintaining that his misconduct—later characterized as grave slander (and effectively as libel when committed in writing)—justified his dismissal.
Torreda subsequently filed a petition for review before the Supreme Court, which ultimately denied his petition, upholding the decisions and underlying administrative findings.

Whether Torreda’s dismissal was justified based on the allegations of grave slander/libel arising from his unauthorized accusations against his superior, Sepulveda.
Whether the fabrication of a robbery charge, despite being a reaction to perceived harassment, could constitute serious misconduct under the applicable labor laws and company policies.

Whether Torreda was afforded due process, considering the timing and manner in which disciplinary actions were taken, including the issuance of warnings and the requirement to submit written explanations.
Whether the administrative proceedings provided him with an adequate opportunity to contest the charges and clear his name before dismissal.

Whether the evidence sufficiently demonstrated that Torreda’s allegations were baseless and malicious, thereby justifying his dismissal.
Whether there existed any error in the sequence of disciplinary events, such as the opening of his drawer, approval from higher management, and the subsequent actions taken by HR.

Whether the NLRC and Court of Appeals committed a grave abuse of discretion in affirming the dismissal on the basis of serious misconduct.
Whether the resolution of factual disputes (such as the authenticity and intent behind Torreda’s email) should preclude judicial intervention on questions of administrative action.