Title
Uniwide Sales Warehouse Club vs. National Labor Relations Commission
Case
G.R. No. 154503
Decision Date
Feb 29, 2008
A managerial employee was terminated for loss of trust due to alleged misconduct; SC upheld dismissal, citing just cause and due process compliance.
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Case Digest (G.R. No. 154503)

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:

  1. Whether the Court of Appeals erred in sustaining the National Labor Relations Commission’s (NLRC) finding that Kawada was constructively dismissed.
  2. Whether Kawada was denied due process in her termination.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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.


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