Case Summary (G.R. No. 228449)
Applicable Law
This case is governed by the 1987 Philippine Constitution and relevant provisions of the Labor Code regarding employment termination based on just causes.
Facts of the Case
Aluag was employed as BIRMPC's cashier from November 16, 1994, until her termination on October 31, 2013. Her responsibilities included managing financial transactions, such as receiving payments, depositing collections, and recording fixed deposits. She began reporting financial information in writing in 2010, following an instruction from her supervisor. On July 16, 2013, shortly before going on maternity leave, she was temporarily relieved from her duties pending an investigation into suspicious loan activity involving her and other employees. Aluag submitted a response after the investigation period, acknowledging certain infractions but attributing knowledge of these issues to her supervisor.
On August 1, 2013, during her maternity leave, she received a preventive suspension notice, which she contended was illegal and subsequently filed a complaint for illegal suspension with the National Labor Relations Commission (NLRC). However, while this complaint was pending, she was terminated on October 31, 2013, prompting her to amend her complaint to allege illegal dismissal.
Respondents' Position
The respondents asserted that Aluag's termination was justified due to loss of trust and confidence, citing serious infractions that negatively impacted BIRMPC's financial status amounting to more than P35 million. These allegations included the improper handling of checks and failing to disclose vital financial information.
Labor Arbiter's Ruling
The Labor Arbiter ruled in favor of BIRMPC, finding that Aluag had been validly dismissed for cause, namely, the loss of trust and confidence based on her position as a cashier. The Arbiter ordered BIRMPC to compensate Aluag with her 13th month pay and service incentive leave pay for 2013 but dismissed her illegal dismissal claim.
NLRC Ruling
Upon appeal, the NLRC overturned the Labor Arbiter's decision, declaring Aluag had been illegally dismissed and ordering substantial financial awards including back wages and separation pay. The NLRC found that the infractions cited were insufficient grounds for dismissal, as they did not amount to violations of Aluag's ministerial duties.
Court of Appeals Ruling
The Court of Appeals (CA) reversed the NLRC ruling and reinstated the Labor Arbiter's decision, concluding that Aluag's conduct constituted serious misconduct justifying her dismissal due to the trust-based nature of her position as cashier. The CA held that Aluag had the responsibility to ensure proper handling of all financial transactions and dismissed her claims that she should not be accountable for checks not deposited.
Issue Before the Supreme Court
The issue before the Supreme Court was whether the CA properly reversed the NLRC’s ruling, concluding that BIRMPC had just cause to terminate Aluag's employment.
Supreme Court's Ruling
The Supreme Court held the petition by Aluag to be without merit for multiple reasons. It noted that
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Case Background
- The case arises from a petition for review on certiorari regarding the decision and resolution of the Court of Appeals (CA) that reversed the ruling of the National Labor Relations Commission (NLRC) and reinstated the Labor Arbiter's (LA) decision.
- The petitioner, Grace R. Aluag, was employed as a cashier by the BIR Multi-Purpose Cooperative (BIRMPC) from November 16, 1994, until her termination on October 31, 2013.
- Aluag's duties included managing financial transactions, issuing checks, and depositing collections, among other responsibilities.
Facts of the Case
- Aluag reported to the Board of Directors about various financial matters and was required to give both verbal and written reports on BIRMPC's funds.
- In July 2013, Aluag received a letter temporarily relieving her from her position pending an investigation of suspicious loans.
- Following her maternity leave and a preventive suspension, she was formally terminated from her employment.
- BIRMPC claimed that Aluag was dismissed due to loss of trust and confidence arising from multiple infractions related to her duties.
LA Ruling
- The Labor Arbiter ruled on May 26, 2014, dismissing Aluag's complaint for illegal dismissal due to lack of merit.
- The LA found that Aluag held a position of trust and confidence, and her infractions resulted in significant financial dam