Case Summary (G.R. No. 97817)
Incident Overview
On September 28, 1988, an altercation occurred when Santos was confronted by Bautista regarding his use of another person's identification card. Santos reacted aggressively—shouting profanities and subsequently destroying food items in the canteen. He escalated the situation by physically assaulting Bautista, inflicting slight injuries upon her. Following this incident, Bautista reported Santos's actions to company management, leading to administrative proceedings against him.
Administrative Proceedings
Upon receipt of Bautista's complaint, the personnel manager, Jesus Perez, required Santos to provide a written explanation for his conduct. On October 1, 1989, Santos submitted an explanation, admitting his actions but attributing them to intoxication. Nevertheless, on October 17, 1988, he was officially terminated from employment for "gross misconduct seriously violative of (the) company rules and regulations."
Legal Action by Bautista
After her workplace incident with Santos, Bautista filed a complaint with the “Lupong Tagapayapa” of Barangay Orando. Following this, she pursued a complaint of slight physical injuries against Santos in the Municipal Trial Court of Pasig, Metro Manila; however, she ultimately executed an affidavit of desistance, leading to the dismissal of that complaint.
Complaint for Illegal Dismissal
Santos, along with the workers' union, filed a complaint for illegal dismissal against Aris Philippines, Inc. On July 21, 1989, Labor Arbiter Edilberto J. Pangan ruled in favor of Santos, ordering his reinstatement without back wages but qualifying the period of absence as a penalty for his misconduct. The ruling suggested that Santos's misconduct did not have implications for his employment.
NLRC Confirmation
The NLRC later affirmed the Labor Arbiter's ruling on December 28, 1990, indicating that Santos's actions, while misconduct, were not directly connected to his work responsibilities and did not disrupt company operations. The NLRC stated that the severity of the penalty of dismissal did not ali
...continue readingCase Syllabus (G.R. No. 97817)
Case Background
- The case involves a petition for certiorari filed by Aris Philippines, Inc. against the National Labor Relations Commission (NLRC) and other respondents, concerning the dismissal of Arnel Santos.
- The case was decided by the Third Division of the Supreme Court on November 10, 1994, under G.R. No. 97817.
Incident Overview
- On September 28, 1988, Arnel Santos was questioned by Eufemia Bautista regarding his use of someone else's identification card.
- In response, Santos displayed aggressive behavior, shouting invectives and threatening to throw away food items in the canteen.
- Following this display, he slapped Eufemia, causing her to fall and sustain slight contusions.
Company Response
- A report of the incident was submitted by the security officer to company officials.
- Eufemia Bautista filed a written complaint against Santos with Jesus Perez, the personnel manager.
- Santos was required to submit a written explanation regarding the incident, which he did on October 1, 1989, admitting his misconduct but attributing it to intoxication.
Termination of Employment
- On October 17, 1988, Santos received a letter of termination citing "gross misconduct seriously violative of (the) company rules and