Title
Supreme Court
Vergara vs. National Labor Relations Commission
Case
G.R. No. 117196
Decision Date
Dec 5, 1997
Employee acquitted of theft but dismissed for loss of trust; SC upheld dismissal, citing substantial evidence of misconduct despite acquittal.

Case Digest (G.R. No. 212362)
Expanded Legal Reasoning Model

Facts:

  • Employment and Incident Background
    • Petitioner Ladislao P. Vergara was employed by Aris Philippines, Inc. as a puncher starting February 20, 1986, earning a daily wage of P64.00.
    • His routine involved reporting to work, proceeding to designated work areas, and following established company practices (e.g., leaving his bag containing a reversible jacket at the guard house or storage area).
    • On November 7, 1987, during his work routine, while at the main gate where routine frisking of bags was conducted, a security guard discovered that the contents of his bag had unexpectedly changed. Instead of his jacket, the bag contained various pieces of uncut leather.
  • Discovery, Investigation, and Termination
    • Alleging the anomaly, the guard requested that petitioner open his bag, leading to the discovery of the uncut leather.
    • Petitioner explained that he was unaware of how the leather came to be in his bag or who might have placed it there.
    • Not satisfied with his explanation, petitioner was brought to the Personnel Manager and subsequently was taken to the Pasig Police Station, where he was detained without counsel until November 12, 1987.
    • A criminal case for attempted qualified theft was filed against him (Criminal Case No. 4295) and, though he was eventually acquitted on August 17, 1988, his employment was already terminated retroactively to November 7, 1987.
    • Despite submitting a letter of explanation and denying any wrongdoing, petitioner’s employment was terminated on the grounds of gross misconduct and loss of trust and confidence.
  • NLRC Proceedings and Labor Arbiter’s Decision
    • Petitioner filed a complaint for illegal dismissal before the labor arbiter, alleging that his dismissal was unjustified given his subsequent acquittal in the criminal case.
    • During the hearing on the merits, petitioner appeared as the sole witness and presented documentary evidence such as his termination letter and criminal case documents, while respondent relied largely on documents and certified transcripts from the criminal proceeding.
    • The labor arbiter ruled in favor of petitioner by finding the dismissal illegal, ordering his reinstatement to his former position with backwages from the termination date, and awarding attorney’s fees (10% of the monetary award).
  • NLRC and Subsequent Procedural Developments
    • Private respondent (Aris Philippines, Inc.) failed initially to post the required supersedeas (appeal) bond within the prescribed reglementary period, causing its appeal to be dismissed by the NLRC on May 31, 1991.
    • The NLRC later reconsidered this dismissal by ordering respondent to post an appeal bond amounting to P59,904.00 and eventually set aside the labor arbiter’s decision, replacing it with a new decision dismissing petitioner’s complaint.
    • Petitioner filed a motion for reconsideration, which was denied by the NLRC in its Resolution of August 17, 1994, prompting the present petition for certiorari before the Court.

Issues:

  • Posting of Supersedeas Bond
    • Whether an employee’s claim for reinstatement and backwages can be affected by the respondent’s failure to post the appeal bond promptly.
    • Whether the absence of a computed monetary award in the labor arbiter’s decision invalidates or precludes the prosecution of the appeal bond requirement.
  • Effect of Criminal Acquittal on Employment Reinstatement
    • Whether the petitioner, being acquitted of the criminal charge of qualified theft for lack of proof beyond reasonable doubt, is automatically entitled to reinstatement and backwages, considering his dismissal stemmed from the same act that led to the criminal case.
  • Evaluation of the NLRC’s Denial of Motion for Reconsideration
    • Whether the NLRC’s Order denying petitioner’s motion for reconsideration was based merely on issues of form and style rather than on a substantive evaluation of the evidence and legal standards.
    • Whether such emphasis on procedural aspects amounts to grave abuse of discretion.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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