G.R. No. 255864 - Universal Robina Corporation vs. Roberto De Guzman Maglalang

Roberto De Guzman Maglalang began working as a machine operator for Universal Robina Corporation (URC) on November 17, 1997.
On March 26, 2015, while cleaning his motorcycle seat in the company parking lot using company-provided alcohol, Roberto encountered difficulties when a security guard noticed a bottle in his bag.
Realizing that the bottle still contained the company’s ethyl alcohol, Roberto panicked and discarded it before it could be retrieved.
The bottle, once recovered by the security guard, was found to contain company property, prompting further action.

Following the discovery, Roberto was brought to the police station where he was subsequently criminally charged with qualified theft.
He was detained for five days and subjected to a preventive suspension initially set for 30 days, later extended for another 30 days.
On March 27, 2015, URC issued a Notice to Explain, requiring Roberto to submit a written explanation within five days; although he submitted his explanation through the union, URC refused to accept it.

In an administrative hearing held on April 27, 2015, Roberto admitted to taking the bottle but denied the charge of theft.
URC, unconvinced by his explanation, issued a Notice of Termination on May 14, 2015.
During the pendency of the criminal case, URC received several apology letters from Roberto pleading for withdrawal of the criminal case and reinstatement; however, URC denied his requests.

On July 15, 2016, URC and Roberto entered into a compromise agreement wherein both parties waived any claims related to the criminal theft.
Despite the agreement, URC denied Roberto’s request for reinstatement and payment of money claims.
Roberto filed an illegal dismissal case against URC after his criminal case was eventually dismissed on August 23, 2016.
The Labor Arbiter dismissed Roberto’s claim for lack of merit but ordered URC to pay a modest amount representing the balance of his money claims after deducting certain government loans.

The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s findings, upholding that Roberto was validly dismissed for serious misconduct.
Roberto, unable to secure reconsideration at the NLRC level, elevated the matter by petitioning the Court of Appeals (CA) on the ground of grave abuse of discretion.
On September 15, 2020, the CA ruled that Roberto was only guilty of simple misconduct given the minimal value (P60.00) of the alcohol and his long-standing, clean service record.
The CA granted Roberto separation pay in lieu of reinstatement along with backwages, although URC’s subsequent motion for reconsideration was denied on February 8, 2021.

URC argued that Roberto’s act of taking the company’s alcohol, regardless of its minimal value, constituted theft—an act of serious misconduct accompanied by a willful breach of trust, justifying his dismissal under the Labor Code.
Roberto maintained that his misconduct was minor given the recovered property’s value, his long and clean service record, and the fact that he did not hold a position of trust. He also contended that the compromise agreement only pertained to the criminal aspect of the theft and did not bar his labor claim.

Whether the value of the company property involved (P60.00) and its timely recovery should mitigate the gravity of the misconduct and, consequently, the penalty imposed.
Whether the employee’s long tenure and previous clean record are relevant factors mitigating against a dismissal for theft.
Whether the dismissal, as imposed by URC, constitutes a disproportionate penalty in light of the actual circumstances surrounding the incident.
Whether the compromise agreement, which waived claims arising from the criminal theft, precludes Roberto from pursuing an illegal dismissal case under labor laws.
Whether the appropriate remedy should be reinstatement or separation pay, and if backwages and attorney’s fees are warranted under the circumstances.