Facts:

The case involves Uniwide Sales Warehouse Club and Vivian M. Apduhan as petitioners against Amalia P. Kawada, the private respondent. Amalia Kawada began her employment with Uniwide in 1981 as a saleslady and worked her way up to the position of Full Assistant Store Manager by 1995, earning a monthly salary of P13,000.00. Her responsibilities included managing various departments and ensuring compliance with company policies. In 1998, Uniwide received complaints regarding Kawada's performance, leading to a series of memoranda issued by Apduhan, the store manager, detailing allegations of unsatisfactory performance, including the mishandling of inventory and allowing unauthorized access to restricted areas.

Kawada responded to these allegations but was deemed unsatisfactory by Apduhan, who continued to issue memoranda outlining further alleged infractions. On July 27, 1998, Kawada sought medical attention for hypertension and was advised to take sick leave. Upon returni...

Facts:

Employment Background

• Amalia P. Kawada (private respondent) began working at Uniwide Sales Warehouse Club (Uniwide) in 1981 as a saleslady. She rose through the ranks and became a Full Assistant Store Manager by 1995, earning a monthly salary of P13,000.00.

Allegations of Misconduct

• In 1998, Uniwide received reports of irregularities in the departments managed by Kawada, including:
  • Commingling of good and damaged items.
  • Selling damaged toys and ready-to-wear items at unreasonable prices.
  • Failure to submit inventory reports.
• On March 15, 1998, Uniwide issued a memorandum to Kawada, asking for explanations and concrete plans to address these issues. Kawada responded on March 23, 1998, but Uniwide found her explanations unsatisfactory.

Further Allegations and Confrontation

• On June 30, 1998, Uniwide issued another memorandum detailing additional allegations against Kawada, including:
  • Allowing unauthorized persons into restricted areas.
  • Falsification of company records.
  • Sleeping during work hours.
  • Unauthorized purchase of damaged items.
• On July 31, 1998, Kawada sought medical attention for hypertension and was advised to take sick leave. She presented a medical certificate to Apduhan (Store Manager), but due to a clerical error (wrong surname on the certificate), Apduhan allegedly shouted at her, causing Kawada to collapse.

Legal Actions

• Kawada filed a police report and obtained a corrected medical certificate. She also sent a letter to Apduhan, accusing her of harassment and creating a hostile work environment.
• On August 2, 1998, Apduhan issued a memorandum scheduling a hearing for Kawada on August 12, 1998, to address the allegations. Kawada filed a complaint for illegal dismissal on August 3, 1998, before the Labor Arbiter (LA).

Termination

• On September 1, 1998, Uniwide terminated Kawada’s employment, citing violations of company rules, abandonment of work, and loss of trust and confidence.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Constructive Dismissal: The Court held that constructive dismissal requires evidence that the employer made continued employment impossible, unreasonable, or unbearable. Kawada’s allegations of harassment and hostile work environment were unsupported by substantial evidence. The memoranda issued by Uniwide were part of its disciplinary process and did not constitute harassment.

2. Due Process: The Court found that Kawada was given ample opportunity to explain her side through the memoranda and the scheduled hearing on August 12, 1998. Her failure to attend the hearing and her mistaken belief that she had been constructively dismissed did not negate the due process afforded to her.

3. Loss of Trust and Confidence: As a managerial employee, Kawada’s position required a higher degree of trust. The evidence presented by Uniwide, including reports and testimonies from employees, provided a reasonable basis for the loss of trust and confidence, justifying her dismissal.

4. Abandonment of Work: The Court ruled that Kawada’s failure to report for work after the August 8, 1998, notice did not constitute abandonment, as there was no clear intent to sever the employer-employee relationship. However, her termination was still valid based on the just causes cited by Uniwide.

5. Social Justice and Fairness: The Court emphasized that while labor rights are protected, employers also have the right to discipline employees, especially those in managerial positions, for valid reasons. The balance between labor rights and management prerogatives must be maintained.

Conclusion:

The Supreme Court granted the petition, reversing the decisions of the NLRC and the Court of Appeals, and dismissed Kawada’s complaint for illegal dismissal. The Court upheld Uniwide’s termination of Kawada based on loss of trust and confidence and compliance with due process requirements.