Case Summary (G.R. No. 246531)
Factual Background
During the team building activity, it was reported that San Juan engaged in inappropriate behavior while under the influence of alcohol. San Juan allegedly attempted to jump into a pool from a second-floor balcony and was later found in a room designated for female employees with his subordinate, Ruben Cruz (Cruz). The event led to allegations of sexual misconduct against San Juan, which were initially reported to the Head of Human Resources of Regus, Maria Isabel Bernal.
Investigation and Allegations
Following the incident, Regus conducted an investigation, interviewing multiple employees who provided inconsistent accounts of the events. Cruz alleged that San Juan attempted to sexually assault him during the incident. In contrast, San Juan denied these allegations, claiming that Cruz was the one who molested him. San Juan also faced additional scrutiny for discussing the incident with other employees during the investigation.
Disciplinary Actions
Regus placed both San Juan and Cruz under preventive suspension pending the investigation, issuing several Notices to Explain, accusing San Juan of violations of the company's policies, including indecent behavior, acts violating sexual harassment laws, and willful breach of trust. San Juan failed to provide a timely written explanation, leading to an administrative hearing, where he reiterated his innocence but acknowledged his intoxication during the incident.
Termination and Legal Proceedings
On August 20, 2014, San Juan was formally terminated, with Regus citing his severe misconduct as just cause for dismissal. San Juan contested his termination, claiming it was illegal and asserting that there was insufficient evidence for his dismissal. His initial complaint was dismissed by the Labor Arbiter (LA), who found just cause for his dismissal under Article 282 of the Labor Code but ordered Regus to pay his 13th-month benefit.
NLRC and CA Rulings
San Juan appealed to the National Labor Relations Commission (NLRC), which initially ruled in his favor, stating that Regus failed to establish San Juan's role as one of trust and that his dismissal was too harsh. However, upon Regus's petition for certiorari, the Court of Appeals (CA) reinstated the decision of the LA, concluding that sufficient grounds existed for San Juan's termination due to loss of trust and confidence.
Supreme Court Ruling
The Supreme Court ruled that no grave abuse of discretion occurred in the CA's decision, emphasizing the need for just cause in terminating an employee
...continue readingCase Syllabus (G.R. No. 246531)
Overview of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by Benedict Princer San Juan against Regus Service Centre Philippines B.V.
- The petition contests the Decision dated October 18, 2018, and the Resolution dated April 5, 2019, of the Court of Appeals, which reversed a prior ruling from the National Labor Relations Commission (NLRC) and reinstated a Labor Arbiter's dismissal of San Juan's complaint for illegal dismissal.
Background Facts
- Benedict Princer San Juan was employed as a Network Operations Manager at Regus until his termination on August 20, 2014.
- A team-building activity was held from June 12 to 14, 2014, which was marred by an incident involving San Juan and his subordinate, Ruben Cruz.
- An internal investigation revealed that San Juan was heavily intoxicated during the event, attempted reckless behavior, and engaged in inappropriate conduct with Cruz, leading to allegations of sexual molestation and misconduct.
Incident and Investigation
- The incident involved excessive alcohol consumption, attempted jumping into a pool, and sleeping arrangements that violated company protocols.
- Cruz accused San Juan of sexual molestation, while San Juan denied the allegations, claiming instead that Cruz molested him.
- Regus conducted interviews with other employees to gather evidence, resulting in conflicting accounts and further comp